State of Connecticut v. Dennis Kono

Summary

The court held that a warrantless canine sniff directed at the front door of a condominium unit, conducted from a shared hallway, is a search under article first, § 7, of the Connecticut constitution. Because the state did not obtain a warrant supported by probable cause before conducting the sniff, the evidence later seized under a warrant based on the canine alert was properly suppressed. Justice Espinosa, dissenting, would have held that the sniff was not a search because the shared hallway was not curtilage and a trained dog was not equivalent to sense-enhancing technology.