Indiana adopts the drug dog rule that “a K9’s instinctive entry into a vehicle does not implicate the Fourth Amendment so long as it is not directed, encouraged, or facilitated by officers.” This one was, and without probable cause, and the search is suppressed. Ocampo v. State, 2025 Ind. App. LEXIS 286 (Aug. 29, 2025).

“The parents do not dispute this evidence but argue that the district court erred by ‘neglect[ing] to focus’ on the ‘actual events at the time of the removal.’ They emphasize that when Detective Wilson removed the children, she did not see drugs or drug paraphernalia, the children were reasonably clean and well-nourished, and there was no ‘immediate evidence’ of drug exposure. But the ultimate question is whether her suspicion was reasonable at the time of removal—not whether evidence supporting it appeared contemporaneously. See Stanley, 899 F.3d at 629 (‘[W]hether there was reasonable suspicion of child abuse warranting removal must be determined by analyzing the totality of the circumstances at the time of the removal.’). The ‘totality of the circumstances’ includes evidence of child abuse Detective Wilson already ‘knew [of] at the time.’ See United States v. Slater, 979 F.3d 626, 629 (8th Cir. 2020) (citation omitted). We do not ask an officer to turn a blind eye to recent, credible evidence of endangerment because there was not more evidence at the moment of removal.” Welter v. Wilson, 2025 U.S. App. LEXIS 22256 (8th Cir. Aug. 29, 2025).*