A public housing employee came to an apartment to check for damage from a sewer back up. She knocked, got no answer, and entered defendant’s apartment. Inside, she found two unconscious persons and “drugs and things.” She called the police. That was a valid private search, following United States v. Couch, 378 F. Supp. 2d 50, 58 (N.D. N.Y. 2005) which held public housing employees in a similar situation were not "government actors" for purposes of the Fourth Amendment (same result under state constitution). State v. Brittingham, 2013 Kan. LEXIS 62 (February 15, 2013).
Cracked windshield can support a stop as a defect in equipment. Villanueva v. State, 2013 Ark. 70 (February 21, 2013).*
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