Duane Jadrich v. State of Indiana, 999 N.E.2d 1022

Deputy Butterfield attempted to serve a civil protective order at 8055 North State Road 267 in Brownsburg and encountered no one at the front door.
Butterfield walked to the back of the property, passing through a chain‑link fence with signs and a closed gate to reach the back door area.
From the back yard, Butterfield observed a circle of firewood with a pile of brush and a grow site containing marijuana plants, prompting him to call his supervisor.
Sergeant Clark and detectives Sadler and Wing arrived; Sadler announced at the front door and then spoke with Jadrich, who allowed entry and consented to a search.
A smoking pipe with marijuana residue was found inside the home, and six marijuana plants were found in the back yard; Jadrich was charged with marijuana possession and paraphernalia possession.
Jadrich moved to suppress the evidence; the trial court denied suppression; at a bench trial, the court convicted Jadrich as charged and sentenced him.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether entry into the curtilage violated the Fourth Amendment	Jadrich argued Butterfield entered curtilage unreasonably.	State contends entry was justified for service of the protective order and officer safety.	Entry into the back yard violated Fourth Amendment; suppression vacated convictions.
Whether consent to search was valid without counsel advisement per Pirtle	Consent was coerced or invalid due to lack of counsel advisement.	Consent was voluntary and not tied to custodial interrogation.	Not necessary to reach Pirtle issue; court holds entry invalid, rendering suppression dispositive.

Hardister v. State, 849 N.E.2d 563 (Ind. 2006) (backyard entry justified by observed activity and pursuit of investigation)
Divello v. State, 782 N.E.2d 433 (Ind. Ct. App. 2003) (courts consider curtilage factors and visitor's route for reasonable access)
Trimble v. State, 842 N.E.2d 798 (Ind. 2006) (purpose of visit relevant to curtilage openness and intrusion analysis)
U.S. v. Dunn, 480 U.S. 294 (1987) (curtilage extent depends on proximity, enclosure, use, and protection from observation)
Hester v. United States, 265 U.S. 57 (1924) (curtilage protection concept foundational to Fourth Amendment)
Oliver v. United States, 466 U.S. 170 (1984) (curtilage determined by intimate activity and home privacy expectations)
California v. Ciraolo, 476 U.S. 207 (1986) (curtilage analysis includes property features and visibility considerations)
Hardesty v. Hamburg Township, 461 F.3d 646 (6th Cir. 2007) (courts allow curtilage entry for investigative purposes when front door approach fails)
U.S. v. Taylor, 458 F.3d 1201 (11th Cir. 2006) (partial departure from front door may not violate Fourth Amendment)
U.S. v. Anderson, 522 F.2d 1296 (8th Cir. 1977) (backyard entry permissible when observations support investigation)