MN: Apt building common hallway not curtilage under Jardines for dog sniff

Dog sniff in the common hallway of an apartment building wasn’t unreasonable because it’s not curtilage under Jardines. State v. Edstrom, 2018 Minn. LEXIS 446 (Aug. 15, 2018).

There was nexus: “Here, the investigating officer had significant experience. The officer identified Logan as a resident of the single-family home to be searched. The investigating officer knew Logan had a history of drug use. The investigating officer personally observed activity in the home consistent with drug use and trafficking. The officer conducted a trash pull from trash left outside the residence and found paraphernalia, marijuana, and methamphetamine. The application for the warrant was submitted immediately after the trash pull was conducted. These facts, in addition to the remainder of the facts set forth in the application, when considered together and not in isolation, provide a substantial basis for the issuing judge to find probable to issue the warrant.” State v. Logan, 2018 Iowa App. LEXIS 746 (Aug. 15, 2018).*

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