Brian Stone v. Todd Martin, 17-1150

Brian and Ellen Stone own a secluded 75-acre parcel; their home and a detached law office are set well back from Route 115 and not visible from public ways. A gated driveway with posted "Keep Out" signs is the only entrance.
Monroe County Deputy Jason Dunlap attempted to serve Ellen Stone with small-claims process; multiple morning attempts found the driveway gate locked and a service card left in the mailbox.
On June 17 Dunlap parked, went around the locked gate on foot, walked the driveway, and approached the detached law office (not the house). He spoke with Ellen (who said, "You found me"), served process, briefly answered Brian Stone’s questions, and left.
The Stones sued under 42 U.S.C. § 1983 asserting Fourth Amendment search and seizure claims against Dunlap and a supervisory policy claim against Sheriff Martin; they also alleged Pennsylvania constitutional and state-law claims.
The district court granted summary judgment for defendants on federal claims and declined supplemental jurisdiction over state claims; the Stones appealed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Dunlap’s entry and brief interaction constituted a Fourth Amendment seizure of property	Stones: deputy’s entry onto private property and interaction interfered with possessory interests (seizure)	Defendants: brief presence and conversation did not meaningfully interfere with possessory interests	Held: No seizure — conduct did not rise to meaningful possessory interference
Whether Dunlap’s conduct was a Fourth Amendment search	Stones: stepping onto private driveway and approaching buildings intruded on protected curtilage/privacy	Defendants: area was open fields/unprotected; no attempt to obtain information beyond service	Held: No search — area treated as open fields under curtilage factors; no Fourth Amendment protection applied
Whether Sheriff Martin is liable for policy permitting such conduct	Stones: county policy allowed unlawful entries; Martin set policy	Defendants: underlying conduct not unconstitutional, so no supervisory liability	Held: No supervisory liability because no Fourth Amendment violation by deputy
Whether the district court should retain supplemental jurisdiction over state-law claims	Stones: merits warrant federal resolution or efficiency favors retention	Defendants: district court properly declined once federal claims dismissed	Held: District court did not abuse discretion in dismissing state claims without prejudice

Soldal v. Cook Cty., 506 U.S. 56 (seizure requires meaningful interference with possessory interests)
United States v. Jacobsen, 466 U.S. 109 (seizure occurs when government asserts dominion and control)
Katz v. United States, 389 U.S. 347 (reasonable expectation of privacy test for searches)
Florida v. Jardines, 569 U.S. 1 (physical intrusion on curtilage is a search)
Oliver v. United States, 466 U.S. 170 (open fields are not protected by Fourth Amendment)
United States v. Dunn, 480 U.S. 294 (four-factor test for curtilage analysis)
Hedges v. Musco, 204 F.3d 109 (factors for declining supplemental jurisdiction)