State v. TalkingtonAnnotate this Case
Defendant was visiting the home of a long-time acquaintance when police officers arrived. One of the officers walked to the backyard of the property and found a baggie of methamphetamine on the ground. Defendant was arrested and transported to jail, where officials discovered a baggie of marijuana during an inventory search of Defendant's belongings. Defendant was charged with several drug-related crimes. The district court granted Defendant’s motion to suppress, concluding that the methamphetamine was found in the curtilage of the home, that a social guest such as Defendant has standing to assert a host’s Fourth Amendment rights in the curtilage, and that marijuana found on Defendant was fruit of the poisonous tree. The Court of Appeals reversed. The Supreme Court reversed the Court of Appeals and affirmed the district court, holding (1) the Court of Appeals erred in reversing because the district court’s findings that the backyard was curtilage were supported by substantial competent evidence, and case law supported its legal conclusion that the area was curtilage; (2) a social guest has standing to challenge a search of the curtilage of the host’s residence; and (3) the marijuana should be suppressed as fruit of the poisonous tree.