Officers entered an apartment building with the consent of one of the tenants when they were investigating a threat with a firearm by one of the tenants. Their knock-and-talk at defendant’s door was reasonable, as was ordering him to open the door under the totality of circumstances. Officers were justified in entering when defendant made a furtive gesture with his hands. State v. Morrow, 2020-Ohio-3390, 2020 Ohio App. LEXIS 2320 (2d Dist. June 19, 2020).
Defense counsel wasn’t ineffective for not challenging defendant’s blood draw on Fourth Amendment grounds. The hospital took it in the normal course of treatment and the state didn’t compel it. The state obtained it from the hospital. Davis v. Comm’r of Corr., 2020 Conn. App. LEXIS 193 (June 23, 2020).*