People v. Kofron

3 Citing cases

  1. People v. Brandt

    2019 Ill. App. 4th 180219 (Ill. App. Ct. 2019)   Cited 4 times   1 Legal Analyses

    This procedure has been referred to as a "knock and talk." See Carroll v. Carman , 574 U.S. 13, ––––, 135 S.Ct. 348, 350-52, 190 L.Ed.2d 311 (2014) ; People v. Kofron , 2014 IL App (5th) 130335, ¶ 24, 384 Ill.Dec. 275, 16 N.E.3d 371 ; People v. Woodrome , 2013 IL App (4th) 130142, ¶ 23, 375 Ill.Dec. 87, 996 N.E.2d 1143 ; People v. Redman , 386 Ill. App. 3d 409, 418, 326 Ill.Dec. 899, 900 N.E.2d 1146, 1155 (2008). "The purpose of a ‘knock and talk’ is not to create a show of force, nor to make demands on occupants, nor to raid a residence.

  2. People v. Huber

    2021 Ill. App. 4th 190087 (Ill. App. Ct. 2021)

    Brandt, 2019 IL App (4th) 180219, ¶ 34. Citing People v. Woodrome, 2013 IL App (4th) 130142, 996 N.E.2d 1143, People v. Redman, 386 Ill. App. 3d 409, 900 N.E.2d 1146 (2008), and People v. Kofron, 2014 IL App (5th) 130335, 16 N.E.3d 371, this court stated: "When reviewing a police officer's actions during a 'knock and talk,' our courts have focused on the reasonableness of the officer's actions given the totality of the

  3. People v. Gonzalez

    2019 Ill. App. 2d 170256 (Ill. App. Ct. 2020)

    See People v. Brandt, 2019 IL App (4th) 180219, ¶ 40 (upholding trial court's determination to allow an officer's observations of cannabis in the curtilage of home while conducting a "knock and talk" with defendant (quoting United States v, Hatfield, 333 F.3d 1189, 1194 (10th Cir. 2003) "[W]hen the police come on to private property to conduct an investigation * * * and restrict their movements to places visitors could be expected to go ([e.g.], walkways, driveways, porches), observations made from such vantage points are not covered by the Fourth Amendment.")); contra People v. Kofron, 2014 IL App (5th) 130335, ¶ 23 (upholding the trial court's determination to suppress an officer's observation of evidence of methamphetamine manufacturing in curtilage of home because evidence "would not have been seen but for the violation of the curtilage"). ¶ 35 Lindley continued his investigation by knocking on the side door and, having received no answer there, the front door to ensure his and the other officers' safety. Thus, Lindley had a legitimate reason to walk toward the front door when he observed the open window.