May-Shaw v. City of Grand Rapids (Mich. 2019) 2019 US Dist. LEXIS 88425

Trespass; Monell Liability; Curtilage;

During an investigation for drug trafficking, LE placed cameras on utility poles and used a surveillance van to confirm subject’s criminal activities. PSD sniffed car parked in front of residence and vehicle in carport assigned to residence. Search warrant was prepared with this information, but described vehicle as parked in an open space, rather than the assigned carport. Subject sues for trespass into the curtilage. Court holds subject failed to state a Monell claim against the agency. Court holds facts pleaded are enough to proceed against the individual officers (very low standard here as subject is pro se inmate and court is required to take at face value the pleadings of the subject). Good outline of curtilage definition.