State v. Bowlds (2019) 2019 Minn.App.Unpub. LEXIS 531

Curtilage; Sniff as Probable Cause

LE informant gave specific details about his dealer including identifying dealer from driver’s license photo. Informant said he had purchased marijuana oil or derivative from dealer. Based on this information, PSD was deployed to sniff at dealer’s apartment door which was in a secured building. PSD alerted to door. A search warrant was issued on the basis of the above information and marijuana products, a gun and cash were seized. The court recognized as precedent State v. Edstrom where the court held that an apartment door in a common hallway is not a violation of curtilage. Dealer did not present any evidence that LE was not allowed in the hallway. Court also found that probable cause existed without the sniff and alert.