Claudia Arroyo v. State, 05-16-00802-CR

Claudia Arroyo was charged with three counts of possession with intent to deliver controlled substances after police found methamphetamine, heroin, and cocaine in her trailer.
Juan Rojas, a Department of Homeland Security/ICE deportation officer, received a tip a deported person was manufacturing/selling narcotics at an Irving trailer home and went to investigate.
When Arroyo opened the front door, Rojas asked if she lived there; she retreated inside, and Rojas smelled a strong odor of marijuana emanating from the trailer.
Rojas notified Irving police, who obtained and executed a warrant to search the trailer and recovered the controlled substances.
Arroyo moved to suppress the evidence obtained in the search; the trial court denied the motion. She pleaded guilty and received deferred adjudication with ten years of community supervision.
On appeal, Arroyo argued Rojas’s entry onto the curtilage was an unconstitutional search under Florida v. Jardines and thus tainted the warrant-based search.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Rojas’s entry onto the curtilage to investigate constituted an unlawful Fourth Amendment search that invalidated the subsequent warrant search	Arroyo: Rojas entered curtilage to investigate a crime without implied invitation so his entry was a search under Jardines and lacked probable cause	State: Rojas approached to knock and speak (a conduct covered by the ordinary implied invitation); no dog sniff or investigatory device was used; any subsequent warrant was valid based on observed odor and investigation	Court: Rejected Arroyo’s claim — Rojas’s conduct was an ordinary knock-and-talk within implied invitation; Jardines (involving a trained dog sniff) is distinguishable; affirmed denial of suppression

Florida v. Jardines, 569 U.S. 1 (2013) (holding bringing a drug-sniffing dog to the curtilage to investigate the home was a Fourth Amendment search)
Kentucky v. King, 563 U.S. 452 (2011) (recognizing an implied license for a visitor to approach a home and knock)