E.D.Mich.: Knock-and-talk was so authoritative, opening door was a detention

“Based on the loud and persistent knocking of two to three minutes, occurring twice during the span of fifteen minutes, the use of an authoritative tone of voice when the officers announced their presence, and the significant police presence at the apartment complex, the Court concludes that any reasonable person inside the apartment would not feel free to refuse to open the door or otherwise terminate the encounter. [¶] Therefore, at the moment Jackson and Jennings finally answered the door, they did so in response to the officers’ show of authority. Because Jackson and Jennings were both seized at that point in time, and the seizure amounted to, at a minimum, an investigatory detention, the officers needed at least reasonable, articulable suspicion of criminal activity to justify the seizure.” The detention was without reasonable suspicion. United States v. Mills, 2019 U.S. Dist. LEXIS 59541 (E.D. Mich. Apr. 5, 2019).

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