MN: Another’s outside storage unit at an apartment building found because its key was found during a search of the apt couldn’t be searched under apt SW

An apartment of another was searched under a warrant, and a key to a storage unit was found. The storage unit was nearby but not in the apartment, and it was in defendant’s name. Searching the storage unit in another person’s name violated the Fourth Amendment. State v. Hill, 2018 Minn. App. LEXIS 423 (Sep. 24, 2018).

911 received a hang up call from a cell phone, and there was a man and a woman screaming. Based on GPS information alone, an officer was dispatched to defendant’s address. He knocked on the door, and fairly corroborated that this was the proper place. Enough information was presented to the officer to justify a warrantless entry for exigency and a protective sweep. State v. Lawrence, 2018-Ohio-3844, 2018 Ohio App. LEXIS 4161 (11th Dist. Sep. 24, 2018).