Knock-and-talk with three questioning officers was inherently coercive

Knock-and-talk by three officers who started off interrogating defendant about drugs was coercive, so the consent was invalid. State v. Frye, 2007 Ohio 6941, 2007 Ohio App. LEXIS 6088 (11th Dist. December 24, 2007):

[*P27] Obviously, there were no exigent circumstances pertaining to the search of Mr. Frye’s RV: this was a pre-planned, warrantless search, relying for its validity solely on his consent. Under the totality of the circumstances, that consent cannot be deemed voluntary. Three police officers, without a warrant and without probable cause, showed up at Mr. Frye’s door, seeking to search his home. This implies coercion. That invalidates his consent. Cf. Robinette at 242-243. While the United States Supreme Court has refused to adopt a “waiver statement” as a requirement for showing a search is voluntary, see, e.g., Robinette at 242, in this case, the police had already obtained a written consent from Mr. Perkins to search his grounds. They could have provided a similar document to Mr. Frye when seeking to search his RV.

Doctor-patient privilege did not protect blood sample drawn by search warrant with probable cause. People v. Elysee, 2007 NY Slip Op 10172, 49 A.D.3d 33, 847 N.Y.S.2d 654 (2d Dept. 2007).