“Here, the Agents did not, in the end, violate the Fourth Amendment. So, the question this Court confronts now is whether the announcement of an unlawful search, which is not in fact completed, render an elicited confession involuntary and inadmissible? The Court holds that it can, and that in this case, it did.” United States v. Sanchez, 2021 U.S. Dist. LEXIS 209398 (D.N.M. Oct. 28, 2021).
The officer entered the curtilage for a welfare check and allegedly exceeded the scope of his limited authority. The trial court’s findings on the look from on the curtilage are inadequate for appeal, and the case is remanded. State v. Calabrese, 2021 VT 76A, 2021 Vt. LEXIS 107 (Oct. 29, 2021).
A compelling governmental need was shown here for lifetime satellite based monitoring. State v. Strudwick, 2021-NCSC-127, 2021 N.C. LEXIS 1019 (Oct. 29, 2021).*