Three officers went to defendant’s mobile home for a knock-and-talk about his overpurchase of pseudoephedrine. Three went because they suspected a meth lab and they didn’t know what to expect. One officer went to the rear and called the others on the cell phone. When the knock and talk occurred, he could see scrambling inside hiding stuff in the kitchen. The unmistakable smell of the meth lab was exigency. [The court doesn’t mention the potential violation of curtilage, but it didn’t seem to matter anyway. They had exigency no matter what.] United States v. Richardson, 2013 U.S. Dist. LEXIS 52349 (N.D. W.Va. April 11, 2013).
Defendant was on supervised release, and he posted a naked picture of himself online portraying in a Santa hat. Five POs, local deputies, and a forensic examiner did a warrantless “parole search” (supervised release, actually) of his place and found pictures on his phone. The PO had reason to conduct the search, and it wasn’t arbitrary. United States v. Hilton, 2013 U.S. Dist. LEXIS 51777 (E.D. Mich. April 10, 2013).*
The consent to search here was limited to entering to retrieve a .410 shotgun. The officer also seized a 20 gauge shotgun, and that violated the terms of the consent and was not otherwise justified. United States v. Gillotti, 2013 U.S. Dist. LEXIS 52402 (D. Me. March 21, 2013).*
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