Case Name: FLORIDA, Petitioner v. Joelis JARDINES
Citation: 133 S.Ct. 1409
Procedural History: Defendant, who was charged with trafficking in cannabis and theft of electricity, moved to suppress evidence seized pursuant to a search warrant that was obtained after a dog-sniff on front porch of defendant's home. The Florida Circuit Court, Miami–Dade County, William Thomas, J., granted the motion. State appealed. The Florida District Court of Appeal, 9 So.3d 1, reversed and certified a conflict. The Florida Supreme Court, Perry, J., 73 So.3d 34, quashed the decision of the District Court of Appeal. Certiorari was granted.
Statement of Facts: In 2006, Detective William Pedraja of the Miami–Dade Police Department received an unverified tip that marijuana was being grown in the home of respondent Joelis Jardines. One month later, the Department and the Drug Enforcement Administration sent a joint surveillance team to Jardines' home where the dog gave a positive alert for narcotics. Based on the alert, the officers obtained a warrant for a search, which revealed marijuana plants; Jardines was charged with trafficking in cannabis. The Supreme Court of Florida approved the trial court's decision to suppress the evidence, holding that the officers had engaged in a Fourth Amendment search unsupported by probable cause.
Issues: Was there a trespassory invasion of curtilage that constituted a search for fourth amendment purposes? Did officers have an implied license for the physical invasion of the curtilage?
Answers: The Supreme Court, Justice Scalia, held that:
Law enforcement officers' use of drug-sniffing dog on front porch of home, to investigate an unverified tip that marijuana was being grown in the home, was a trespassory invasion of the curtilage which constituted a “search” for Fourth Amendment purposes, and officers did not have an implied license for the