CA5: 10 am knock-and-talk didn’t violate Jardines

Officers who came to defendant’s door at 10 am and asked for permission to use a dog to sniff his yard didn’t violate Jardines. United States v. Flores, 2020 U.S. App. LEXIS 10235 (5th Cir. Apr. 1, 2020).

“The present case concerns the search of a parked, unoccupied vehicle in which Wilson claims no property interest. He also claims that he does not own or control the property where the car was parked at the time of the search. As a result, this Court finds that Wilson does not have standing to seek suppression of the items found in the vehicle. Nevertheless, out of an abundance of caution, the Court will consider Wilson’s arguments.” On the merits, “In the present case, investigators were notified by a reliable confidential informant that Wilson was selling heroin from the Carson Drive property. The investigators saw Wilson leave the Carson Drive property, and when they stopped him for a traffic violation, they found narcotics and a weapon in his vehicle. Finally, Wilson told the investigators that he occasionally lived at the Carson Drive property.” United States v. Wilson, 2020 U.S. Dist. LEXIS 57089 (S.D. Miss. Apr. 1, 2020).*