State v. EdstromAnnotate this Case
The Supreme Court held that a warrantless narcotics-dog sniff in the hallway outside Defendant’s apartment did not violate Defendant’s right to be free from unreasonable searches under the Minnesota and United States Constitutions.
A jury found Defendant guilty of first-degree and fifth-degree possession of a controlled substance and possession of a firearm by a prohibited person. The court of appeals reversed the convictions, concluding that the narcotics-dog sniff in the hallway immediately adjacent to Defendant’s apartment door was a search under the Fourth Amendment because it violated Defendant’s reasonable expectations of privacy and that the warrantless search of Defendant’s home was unreasonable. The Supreme Court reversed, holding (1) the police did not intrude upon the curtilage of Defendant’s apartment or his reasonable expectation of privacy when they conducted the dog sniff, and therefore, no Fourth Amendment search occurred; and (2) because the police were lawfully present in the hallway and had a reasonable suspicion of criminal activity, the dog sniff did not violate Minn. Const. art. I, section 10.