State v. Patterson, 304 Kan. 272

Wichita police obtained a warrant to search "the premises of 2720 N. Erie" for drugs, paraphernalia, currency, firearms, and indicia of drug sales; the affidavit named Dontae Patterson and his minor son D.M.P. as residents.
Officers executed the warrant; Patterson was inside the house and D.M.P. sat in the driver’s seat of a white Mercedes parked a few feet from the house, engine off.
In the house officers found marijuana, cocaine residue, a scale, large cash amounts, and a Glock; in the Mercedes they found cocaine residue, a scale, sandwich bags, and a Taurus handgun.
Patterson moved to suppress the evidence from the Mercedes. The district court granted suppression, finding the car was outside the warrant scope and evidence would not have been inevitably discovered.
The Court of Appeals reversed, holding the Mercedes was within the curtilage and thus within the warrant’s scope; the Kansas Supreme Court granted review.
The Kansas Supreme Court affirmed the Court of Appeals: the warrant’s use of "premises" encompassed the Mercedes, and under the adopted Gottschalk test officers reasonably could treat the vehicle as under the control of the residence.

Issue	Patterson's Argument	State's Argument	Held
Whether the search warrant for the "premises" of 2720 N. Erie authorized searching the Mercedes parked at the residence	The Mercedes was a mobile container possibly innocently present and not covered by the warrant; curtilage analysis would not necessarily include the vehicle	Warrant term "premises" and the vehicle’s location/indicia of control bring the car within the warrant’s scope; curtilage or premises include such vehicles	Warrant authorizing search of the premises included the Mercedes; officers reasonably could conclude the vehicle was under resident control and search it under the warrant

Oliver v. United States, 466 U.S. 170 (curtilage defined by expectation of privacy)
United States v. Dunn, 480 U.S. 294 (four-factor curtilage analysis)
United States v. Ross, 456 U.S. 798 (warrant for premises extends to containers that may hold the objects sought)
Ybarra v. Illinois, 444 U.S. 85 (presence at premises alone does not justify searching all persons/containers)
Horton v. California, 496 U.S. 128 (search scope limits under a warrant)
United States v. Gottschalk, 915 F.2d 1459 (10th Cir.) (vehicles on premises included if owned/controlled by resident or objectively appear so)
State v. McClelland, 215 Kan. 81 (term "premises" includes all property part of the unit)
State v. Basurto, 249 Kan. 584 (warrant describing a residence authorizes search of the curtilage)
State v. LeFort, 248 Kan. 332 (warrant specificity and common‑sense interpretation)
State v. Sprague, 303 Kan. 418 ("home" plus areas outside sufficed to describe entire premises)
State v. Ogden, 210 Kan. 510 (outdoor items like a yard trashcan may be part of premises)