Arizona Supreme Court

State of Arizona, Appellee v. Jose Salvador Guillen, Appellant

January 15, 2010223 Ariz. 314

Summary

The court held that the resident’s voluntary consent to search was sufficiently attenuated from an allegedly unlawful exterior dog sniff because she did not know about the sniff and the officers’ conduct was not flagrant. The court therefore concluded that the evidence obtained from the garage should not be suppressed, vacated the court of appeals’ opinion, and affirmed the conviction.