State v. Casatelli, 953 N.W.2d 656

Background

Deputies responded (Oct. 3, 2019) to a loud-party complaint at a residence; they parked down the street and walked up a long driveway.
Deputies saw Casatelli exit the house, enter a vehicle parked in the driveway, and start the engine; a deputy knocked on the window and shined a flashlight; Casatelli shut off the engine and exited the vehicle.
On contact the deputy smelled alcohol and observed bloodshot/watery eyes and slurred speech. Casatelli accompanied deputies toward the house; the house sitter consented to their entry.
A deputy asked Casatelli to go to the front of the house for field sobriety tests; Casatelli performed poorly, consented to an on-site test showing BAC .206, was arrested, and later consented to a breath test.
Casatelli moved to suppress evidence, arguing he was seized in a constitutionally protected area (guest in backyard) without probable cause; the district court denied the motion.
Casatelli entered a conditional guilty plea, preserving the suppression appeal; the Supreme Court affirmed the denial of suppression.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether deputies violated Fourth Amendment by seizing Casatelli in a constitutionally protected area (guest in backyard).	Deputies had reasonable, articulable suspicion based on seeing Casatelli start a vehicle plus signs of intoxication; house sitter consented to entry; detention was investigative and lawful.	Casatelli was a guest with a reasonable expectation of privacy in the backyard; officers coerced him out of the home and seized him without probable cause, so evidence must be suppressed.	Court held deputies had reasonable suspicion from the driveway observations and impairment indicators; Casatelli lacked a recognized expectation of privacy in the backyard; no unconstitutional seizure.
Whether voluntary accompaniment/third-party consent validated officers’ presence and subsequent testing.	House sitter consented to officers’ entry; Casatelli voluntarily accompanied deputies earlier, so entry and further detention were lawful.	Accompaniment was coerced once an officer told him he was not free to leave; third-party consent cannot justify a warrantless in-home seizure of a guest.	Court found third-party consent to enter and Casatelli’s voluntary movement to the backyard did not erase the deputies’ preexisting reasonable suspicion; consent and circumstances supported the officers’ actions.
Whether evidence from field sobriety, portable test, and breath test must be suppressed.	Exclusionary rule inapplicable because detention and entry were lawful; probable cause to arrest arose from tests and observations.	Evidence was fruit of an unlawful seizure inside a protected area and should be excluded.	Court concluded suppression not required; investigative detention and subsequent arrest were lawful under Terry and factual findings.

Key Cases Cited

Terry v. Ohio, 392 U.S. 1 (established standard for investigative detention)
Florida v. Royer, 460 U.S. 491 (investigative stop scope/duration must be reasonably related to justification)
Payton v. New York, 445 U.S. 573 (warrantless, nonconsensual home entries presumptively unreasonable)
Schneckloth v. Bustamonte, 412 U.S. 218 (consent is an exception to warrant and probable-cause requirements)
Florida v. Jardines, 569 U.S. 1 (knock and approach principles re: curtilage and investigative approaches)
Kinsella v. State, 840 N.W.2d 625 (N.D. case recognizing presumptive unreasonableness of warrantless home searches and consent exception)
Olson v. Levi, 870 N.W.2d 222 (officer may approach an already stopped vehicle without reasonable suspicion)
Bridgeford v. Sorel, 930 N.W.2d 136 (knocking on a vehicle window is constitutionally permissible)
State v. Ackerman, 499 N.W.2d 882 (guest’s expectation of privacy in a home can be recognized under certain circumstances)