State of Minnesota v. Cortney John Edstrom

Summary

The court held that a warrantless narcotics-dog sniff at the seam of an apartment door did not violate the Fourth Amendment because the sniff occurred outside the apartment's curtilage and disclosed only the presence or absence of contraband. Although the sniff was a search under the Minnesota Constitution, it was lawful because police were lawfully present in the hallway and had reasonable, articulable suspicion of criminal activity. The court affirmed in part, reversed in part, and remanded to the court of appeals for further proceedings; Justice Lillehaug, joined by Justice Chutich, dissented and would have required suppression because the apartment doorway was part of the home's curtilage.