Police entered defendant’s backyard based on a call about a strong chemical smell. He was grinding glass with a heavy tool. They saw two women and another man visible inside the shed. They ordered him out and then got defendant to sign a consent form. The consent was invalid because the police unlawfully entered the curtilage without exigency. Bryant v. State, 2019 Fla. App. LEXIS 3570 (Fla. 1st DCA Mar. 7, 2019).
The totality of the information showed probable cause for issuance of the search warrant without regard to the challenged show up of defendant. United States v. Hicks, 2019 U.S. Dist. LEXIS 34432 (E.D. N.C. Mar. 5, 2019).*