State v. Gary Monroe Scull, 862 N.W.2d 562

Confidential informant identifies Gary M. Scull as cocaine base distributor and provides Scull's address and vehicle details.
Officer Wiesmueller investigates and verifies informant information using probation status, DOC records, and vehicle registration matching Scull.
Detective Edersinghe brings drug-sniffing dog Voden to Scull's address; dog alerts at the front entry after a brief visit.
Based on the dog's alert and informant information, a warrant is sought and ultimately issued to search Scull's home for controlled substances.
A circuit court commissioner grants the warrant after reviewing the affidavit and determining probable cause; police execute the search and seize cocaine, marijuana, and paraphernalia.
Scull moves to suppress the evidence, arguing the dog sniff was unlawful and tainted the subsequent warrant.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the good faith exception applies to the warrant evidence	Scull argues the warrant relied on an unlawful dog sniff and cannot be saved by good faith.	Scull's adversary argues the good faith exception applies due to substantial pre-warrant investigation and review by a knowledgeable attorney.	Good faith exception applies; evidence not suppressed.
Whether the dog sniff of Scull's home was a Fourth Amendment search	Scull contends the dog sniff at the home was an unlawful warrantless search that contaminated the warrant.	State maintains the dog sniff did not require a warrant under prior Wisconsin precedent; reliance on the warrant remains reasonable.	Court treated the sniff as violating the Fourth Amendment but still applied good faith.

State v. Eason, 245 Wis. 2d 206 (2001 WI 98) (good faith test with investigation and attorney review)
State v. Hess, 327 Wis. 2d 524 (2010 WI) (lead to good faith framework with judicial integrity concerns)
United States v. Leon, 468 U.S. 897 (1984) (established good faith exception to the exclusionary rule)
State v. Ward, 231 Wis. 2d 723 (2000 WI) (deterrence and reasonableness considerations in exclusionary rule)
State v. Miller, 256 Wis. 2d 80 (2002 WI App) (dog sniff of vehicle not a search; privacy interests limited)
State v. Arias, 311 Wis. 2d 358 (2008 WI) (dog sniff of vehicle in public not a search)
Illinois v. Caballes, 543 U.S. 405 (2005) (dog sniff during lawful stop; no privacy interest violation)
United States v. Place, 462 U.S. 696 (1983) (dog sniff of luggage; no search for Fourth Amendment)
Florida v. Jardines, 133 S. Ct. 1409 (2013) (dog sniff at home porch classified as a search)