Andrew Carman v. Jeremy Carroll, 749 F.3d 192

Troopers responded to a dispatch to locate Michael Zita and a stolen car believed to be at the Carmans’ residence; no warrant was obtained.
The Carmans’ home sits on a corner lot with a front path and a back deck; troopers bypassed the front door and entered the backyard toward the garage.
On the back deck, Andrew Carman confronted the troopers; Carroll briefly restrained Carman’s arm after suspecting he might be armed, and Carman fell off the deck.
Karen Carman consented to a house search after the troopers entered the home; the search yielded no Zita or stolen vehicle.
The Carmans sued under 42 U.S.C. § 1983 alleging unlawful entry and unlawful seizure; the district court denied motions for judgment as a matter of law.
The Third Circuit reversed in part and affirmed in part: unlawful entry was violated; unreasonable seizure was supported as reasonable; remanded for judgment in Carmans’ favor on the unlawful-entry claim.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Does warrantless entry into curtilage via back deck violate the Fourth Amendment?	Carman argues knock-and-talk allows entry to front door; back-entry was lawful due to purpose.	Carroll argues knock-and-talk can extend into curtilage when justified by purpose and proximity.	Entry violated Fourth Amendment; knock-and-talk not satisfied.
Was Carroll entitled to qualified immunity for the unlawful-entry violation?	Rights were clearly established by prior case law.	Qualified immunity shields reasonable officers absent clearly established rights.	Rights were clearly established; district court JMOL reversed on unlawful entry.
Was the seizure of Carman reasonable under the Fourth Amendment?	Seizure was unlawful or excessive given lack of evidence.	There was at least minimum evidence to justify an investigatory stop.	There was sufficient evidence to support reasonableness; jury verdict affirmed.
Should the district court’s jury instruction on knock-and-talk be reviewed?	Instruction incorrectly mirrored Jardines and Jardines-based reasoning.	Instruction properly framed; Jardines guidance is consistent with law.	Remainder not addressed on appeal because unlawful-entry reversal dictates remand on that issue.

Jardines v. California, 133 S. Ct. 1409 (2013) (front-door entry required; curtilage entry without invite is a search)
Marasco v. Cristina, 318 F.3d 497 (3d Cir. 2003) (knock-and-talk limited; entering farther into curtilage requires front-door starting point)
Kyllo v. United States, 533 U.S. 27 (2001) ( Nature of Fourth Amendment privacy and physical intrusion analysis)
Payton v. New York, 445 U.S. 573 (1980) (home-entry expectations; warrantless entries generally unlawful)
Breard v. Alexandria, 341 U.S. 622 (1951) (front-door invitation doctrine for visitors; implied license)
Kentucky v. King, 131 S. Ct. 1849 (2011) (exigent circumstances and initial entry considerations)
Adams v. Williams, 407 U.S. 143 (1972) (brief investigatory stop supported by reasonable suspicion)
Dutton v. Wolpoff & Abramson, 5 F.3d 649 (3d Cir. 1993) (standard for evaluating jury verdicts in §1983 cases)
United States v. Williams, 413 F.3d 347 (3d Cir. 2005) (premise for reasonable, investigatory stops)
Kyllo v. United States, 533 U.S. 27 (2001) (reiterated Katz framework for reasonable expectation of privacy)