E.D.Okla.: “No trespassing” signs alone don’t prevent knock-and-talk

“No trespassing” signs alone not enough to create any protection against a knock-and-talk at the front porch. United States v. Dry, 2013 U.S. Dist. LEXIS 59406 (E.D. Okla. March 21, 2013):

To determine if the “knock and talk” conducted by the officers in this case invaded the curtilage of Dry’s home and thus violated the Fourth Amendment, the Court must consider four factors: “the proximity of the area claimed to be curtilage to the home, whether the area is included within an enclosure surrounding the home, the nature of the uses to which the area is put, and the steps taken by the resident to protect the area from observation by people passing by.” United States v. Cavely, 318 F.3d 987, 993-94 (10th Cir. 2003), quoting Dunn, 480 U.S. at 301. Based on these factors, the undersigned Magistrate Judge concludes that the officers did not invade the curtilage of Dry’s home to conduct their “knock and talk.”