State v. Barlow, 2021 Ohio 2191

On January 13, 2019, Sgt. Christopher Schonauer investigated mailboxes run over near the Barlow property after a neighbor identified a possible black pickup belonging to the Barlows.
The Barlow property has a ~700-foot driveway; a large pole barn sat about 200 feet from the driveway entrance and ~500 feet before the house. The pole barn had large doors and a smaller people door.
When the deputy drove up the driveway he observed the pole barn lights on, both large doors open, cars and people inside, and loud music; activities inside were visible from the open door.
The deputy called for Tim Barlow, then pushed the partially open people door to enter and observed a beer-pong game and alcoholic beverages, many attendees appearing under age.
Dakota Barlow, seated in a vehicle inside the barn, turned off the radio, exited, set a bottle down, and approached the deputy; Barlow was charged with an offense involving underage persons and moved to suppress evidence, arguing the barn was within the home's curtilage.
The municipal court denied the suppression motion, convicted Barlow after a bench trial, and this appeal challenged the denial on Fourth Amendment grounds.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the deputy’s pushing open the partially open people door and stepping into the pole barn violated the Fourth Amendment because the pole barn was within the home's curtilage	State: Knock-and-talk was lawful; barn was open and visible from driveway, not curtilage; officer could reasonably enter to contact owner	Barlow: Pole barn was part of home’s curtilage; warrantless entry and opening the door constituted an unlawful search	Court: Entry was lawful. Barn was not functionally private/within curtilage given openness/visibility; knock-and-talk and public access justified entry; suppression properly denied

State v. Burnside, 100 Ohio St.3d 152 (standard for appellate review of suppression rulings)
State v. Dunlap, 73 Ohio St.3d 308 (deference to trial court factual findings)
State v. Fanning, 1 Ohio St.3d 19 (trial court as factfinder on suppression)
Mapp v. Ohio, 367 U.S. 643 (Fourth Amendment applied to states)
Kentucky v. King, 563 U.S. 452 (knock-and-talk as permissible warrantless intrusion)
State v. Young, 31 N.E.3d 178 (presumption of unreasonableness for warrantless home entries; discussion of exceptions)
Ornelas v. United States, 517 U.S. 690 (de novo review of legal questions from suppression facts)
United States v. Arvizu, 534 U.S. 266 (courts give due weight to inferences by local officers)
Welsh v. Wisconsin, 466 U.S. 740 (warrantless home entries presumptively unreasonable)
Pritchard v. Hamilton Twp. Bd. of Trustees, [citation="424 F. App'x 492"] (knock-and-talk described as not requiring objective suspicion)