Police knock and talk led to them hearing noises of someone rushing around inside. They could also smell marijuana from outside, and they had information of buys from inside the house. Exigency established. Hall v. State, CR-20-0394 (Ala. Crim. App. Sept. 3, 2021).
Conducting a FST is a seizure requiring reasonable suspicion. State v. Coyle, 2021-Ohio-3023 (5th Dist. Aug. 31, 2021).
Carpenter not applied retroactively in post-conviction to a 2011 conviction. State v. Jackson, 2021-Ohio-3114 (2d Dist. Sept. 1, 2021).*