## Facts

- Miami-Dade police received an unverified tip that Joelis Jardines’s home was being used to grow marijuana.
- Detectives went to Jardines’s house with a trained narcotics-detection dog.
- The handler led the dog onto the front porch and to the front door, where the dog alerted to the presence of narcotics; an officer also reported smelling marijuana.
- Officers relied on the dog alert and related observations to obtain a search warrant.
- A search of the home revealed marijuana plants, and Jardines was charged with trafficking in cannabis.
- The trial court suppressed the evidence as the product of an unlawful search; an intermediate appellate court reversed; the state supreme court reinstated suppression; the U.S. Supreme Court affirmed.

## Issues

1. Whether bringing a trained narcotics-detection dog onto a home’s front porch to sniff at the front door constitutes a “search” under the Fourth Amendment.
2. Whether officers exceed any implied license to approach a home when they enter the curtilage with a drug-detection dog to gather evidence.
3. Whether evidence obtained under a warrant based on an unconstitutional porch dog sniff must be suppressed.

## Decision

- The Court held, 5–4, that the officers’ use of a trained police dog on the home’s front porch to investigate for drugs was a Fourth Amendment search.
- The Court reasoned that officers obtained information by physically intruding on constitutionally protected property (the home’s curtilage) to gather evidence.
- The front porch is within the curtilage and receives the home’s heightened Fourth Amendment protection.
- While visitors (including police) may approach a front door to speak with occupants, that implied license is limited in area and purpose and does not extend to conducting an evidence-gathering dog sniff.
- The Court found it unnecessary to decide the case under the reasonable-expectation-of-privacy test because the property-based intrusion was sufficient.
- The judgment suppressing the evidence was affirmed.

## Legal Principles

- A Fourth Amendment search occurs when the government physically intrudes on a protected area (including a home and its curtilage) to obtain information.
- The curtilage is treated as part of the home for Fourth Amendment purposes; a front porch is a paradigmatic curtilage area.
- The implied license to approach a home’s front door permits a customary attempt to contact occupants but does not authorize investigative conduct aimed at discovering evidence, such as a drug-detection dog sniff at the door.
- In the home context, warrantless information-gathering intrusions into the curtilage are presumptively unreasonable absent a recognized exception.

## Conclusion

The Court held that using a trained narcotics-detection dog on a home’s front porch to detect drugs at the front door is a Fourth Amendment search because it involves a physical, evidence-seeking intrusion into the home’s curtilage beyond any implied license to approach and knock; the resulting evidence was properly suppressed.


Florida v. Jardines, 569 U.S. 1 (2013)