State v. Edstrom Minnesota Supreme Court Oral Agreement

In State v. Edstrom Minnesota Supreme Court Oral agreement video, the state attorney
argues that there is a difference in scope of protection offered to private homes and apartments.
In private homes, there is a clear distinction between the area that is under protection and that
which is not. On the other hand, apartments have shared areas such as corridors and pavements
that are accessible by other people; hence curtilage rights do not apply. He argues that only in the
case where a specific area in an apartment has been designated for a specific person and is not
accessible to others, and in his case, curtilage rights apply. The state attorney stated that the
curtilage in the apartment applied from below the door and not the outside or hallway. He further
submits that the rule of law provides that the police need reasonable suspicion to conduct a dog
sniff.
Edstrom’s appellate attorney submitted that the curtilage applies from the outside of the
doorway and the area extending to the hallway. He stated that any intrusion by the state needed
plausible cause. He further stated that the area outside the door and extending to the welcome
area or end is under curtilage protection (Minnesota Judicial Branch, 2018). His argument was
that this is the area that a visitor or person stands and knocks at the door and waits to be received.
According to him, this area extends from the apartment, and it is an intimate area that is part of
the inside of the apartment. He further argues that this area that is so intimately connected to the
rest of the apartment requires protection from intrusion.
In the case State v. Edstrom, the state provided that curtilage protection in an apartment
begins from the space below the door and not outside the door. The state attorney argued that this
is because the area outside the door or the hallway is a common area accessible by other people
and tenants and not the owner of the apartment only. He also argued that in a case where the

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police have reasonable suspicion, then it is right for them to investigate or look at an illegal
activity. Intrusion occurs only when legal activities have been investigated in a private area
(Legal Information Institute, 2020). Edstrom, on the other hand, was of the view that the area
outside the door is also treated as the inside as it is an extension of the apartment. He saw this
area as the place where the owner of the apartment receives his visitors and should be treated as
curtilage.
The court of appeal identified the question in this case as to whether allowing narcotic
dogs to sniff in the hallway outside the apartment of the respondent without a warrant violated
the respondents right from intrusion through unreasonable searches. The law applied, in this
case, is the Minnesota Constitution and the United States Constitution. The court held that the
rights of privacy of the respondent were not violated, and the narcotic dog sniff was not a search
as provided under the Fourth Amendment. The court further held that the police acted from
reasonable suspicion of criminal activity, and they were legally present at the apartment; hence
there was no violation of Article 1, Section 10 of the Minnesota Constitution. The decision of the
Supreme court was that the front porch of the house was, in fact, curtilage, and even though this
area was open for other people to pass through, the person still holds the right to no intrusion in
the home as stated under the Fourth Amendment. Curtilage was defined to include the home and
its environs (Ambrose, 2018). The area sniffed by the dog was found to be within the curtilage of
the respondent’s home.
As a police officer, the takeaway from this case would be that it is essential to know the
provisions of the law when gathering evidence to ensure successful prosecutions. Search
warrants are also essential in cases where there is reasonable suspicion. In all investigations, the

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provisions of the Fifth Amendment should be taken into consideration and fulfilled to ensure
citizens’ rights are protected in all cases.

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References

Ambrose, R. (2018, March 31). Minnesota Supreme Court expands 4th Amendment curtilage
protection. Ambrose Law Firm, PLLC. https://ambroselaw247.com/minnesota-supreme-
court-expands-4th-amendment-curtilage-protection/
Legal Information Institute. (2020). Exclusionary rule. LII / Legal Information Institute.
https://www.law.cornell.edu/wex/exclusionary_rule
Minnesota Judicial Branch. (2018, November 4). Minnesota judicial branch – ArgumentDetail.
https://www.mncourts.gov/SupremeCourt/OralArgumentWebcasts/ArgumentDetail.aspx?vid=1
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