United States v. Wells, No. 10-2638 (8th Cir. 2011)Annotate this Case
Defendant was indicted for conspiracy to manufacture methamphetamine and moved to suppress evidence obtained during two searches of an outbuilding behind his house. At issue was whether the district court erred in concluding that defendant had a reasonable expectation of privacy in any part of the unpaved driveway leading up to the outbuilding. The court held that the officers were standing in an area in which defendant had a reasonable expectation of privacy, i.e., the curtilage of his home, when they observed the lighted outbuilding. The court also held that the officers' entry onto the curtilage was not constitutionally reasonable and, in this case, entry into the area could not be justified as a "knock-and-talk." Therefore, the order suppressing the evidence was affirmed.