VA: Knock-and-talk is still a valid exception for entry onto the curtilage

While entry into the curtilage is presumptively unreasonable without a warrant, Collins v. Virginia, 138 S. Ct. 1663, 1670 (2018), there is still implied license for police to enter for a knock-and-talk. Saal v. Commonwealth, 2020 Va. App. LEXIS 241 (Oct. 13, 2020).

“Bechtel argues on appeal that the municipal court’s delay in unsealing the affidavit ‘was significantly prejudicial to appellant and affected her ability to prepare for her defense.’ … We find no error. Bechtel was dilatory in raising the issue in the present case until shortly before the scheduled trial date. She was provided the affidavit the same date she requested it. Moreover, trial did not occur until October 29, 2019, over a month after she was allowed to view the affidavit thus obviating her otherwise vague claim of significant prejudice.” State v. Bechtel, 2020-Ohio-4889, 2020 Ohio App. LEXIS 3732 (11th Dist. Oct. 13, 2020).