CA4: Trash container in open at curb was not on curtilage under Dunn factors

Trash at the curb for pickup was not on the curtilage under Dunn. The area was wide open. United States v. Lipford, 2021 U.S. App. LEXIS 12697 (4th Cir. Apr. 28, 2021).

Factual disputes aside, this much is undisputed: “The district court correctly held that Plaintiff failed to raise a triable issue of fact as to whether Selmanson’s use of lethal force was objectively reasonable. By ignoring repeated lawful orders to drop the gun and instead bringing his left hand over to grip the shotgun with both hands and beginning to raise the barrel up to a ninety-degree angle, Krause created an immediate threat to Selmanson’s life.” Krause v. County of Mohave, 2021 U.S. App. LEXIS 12626 (9th Cir. Apr. 28, 2021).*

Collection of defendant’s CSLI 11 years before Carpenter was reasonable when it happened, and the good faith exception would be applied. People v. Potts, 2021 IL App (1st) 161219, 2021 Ill. App. LEXIS 214 (Apr. 28, 2021).*

What was apparently a drug drop was at least reasonable suspicion for the stop, and seeing the object red bag in the car ripened it to probable cause. United States v. Melo, 2021 U.S. Dist. LEXIS 81123 (S.D. N.Y. Apr. 28, 2021).*

State officials having an administrative warrant that was never served doesn’t state a Fourth Amendment claim. Brimstone Natural Res. Co. v. Haight, 2021 U.S. Dist. LEXIS 81412 (D. Ore. Apr. 28, 2021).*

This entry was posted in Administrative search, Cell site location information, Curtilage, Excessive force, Good faith exception, Reasonable suspicion. Bookmark the permalink.

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