FLORIDA V. JARDINES 133 S.Ct. 1409 (2013) CASE BRIEF

FLORIDA V. JARDINES

133 S.Ct. 1409 (2013)

NATURE OF THE CASE: Florida (P) appealed a decision which approved the suppression of evidence finding no probable cause for the Fourth Amendment search when police took a drug-sniffing dog to Jardines' (D) front porch, resulting in a positive alert for narcotics and issuance of a search warrant.

FACTS: Detective Pedraja received an unverified tip that marijuana was being grown in D's home. A month later, a joint surveillance team watched the home for fifteen minutes and saw no vehicles in the driveway or activity around the home, and could not see inside because the blinds were drawn. Detective Pedraja approached the home accompanied by a trained canine handler and a drug-sniffing dog. As the dog approached the front porch, the dog engaged. After sniffing the base of the front door, the dog sat, which is the trained behavior upon discovering the odor's strongest point. Detective Pedraja applied for and received a warrant to search the residence. The search revealed marijuana plants, and D was charged with trafficking in cannabis. D moved to suppress the marijuana plants on the ground that the canine investigation was an unreasonable search. The trial court granted the motion. The Court of Appeal reversed. The Florida Supreme Court approved the trial court's decision to suppress. The Supreme Court granted certiorari.

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LEGAL ANALYSIS:





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