Florida v. Jardines
Citation: 569 U.S. 1 (2013)
Facts
Miami-Dade police received a tip that marijuana was being grown in Joelis Jardines’ home. Officers brought a drug-sniffing dog to the front porch, where the dog alerted, leading to a warrant and the discovery of marijuana plants. Jardines moved to suppress, arguing the use of the dog at his front door was an unlawful search.
Issue
Whether bringing a trained drug-detection dog onto the porch of a private home to investigate is a “search” within the meaning of the Fourth Amendment.
Holding
The Supreme Court held that the use of a drug-sniffing dog on a homeowner’s porch to investigate the contents of the home is a Fourth Amendment search. The officers engaged in a physical intrusion on a constitutionally protected area (curtilage) for the purpose of gathering information.
Rule
The curtilage of a home receives the same Fourth Amendment protection as the home itself. Bringing a trained dog onto the porch — beyond the implicit license extended to the public — constitutes an unlicensed physical intrusion into a protected area and is a search requiring justification.
Significance
Jardines reaffirmed the trespass-based analysis of United States v. Jones in the home context, holding that the curtilage is constitutionally protected. It pairs with Illinois v. Caballes (dog sniff of car during lawful stop is not a search) to show how the Court applies different rules depending on the location of the sniff.