Vermont v. Calabrese
Annotate this CaseDefendant Devan Calabrese appealed the criminal division’s denial of his motion to suppress evidence of a cartridge found at his girlfriend’s house following a remand from the Vermont Supreme Court. He argued the trial court exceeded the scope of the remand in Vermont v. Calabrese (Calabrese I), 268 A.3d 565, by finding that the search did not occur within the curtilage of the home, and that the evidence did not support the court’s findings that, even if within the curtilage, the trooper’s search did not exceed the trooper’s license to enter the property to conduct a welfare check. Finding no reversible error, the Vermont Supreme Court affirmed.
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