State v. Seidl, 939 N.E.2d 679

Deputy received anonymous tip of meth production at Seidl's residence and approached the property for a knock-and-talk.
From the gravel lot near the residence, the deputy observed McGinnis in a barn through an open window and witness him conceal a foil.
Deputy summoned Seidl, explained the observed activity, and sought consent to search the barn, which Seidl provided after reading a rights form.
The barn search yielded marijuana, methamphetamine, and paraphernalia.
Seidl was charged with maintaining a common nuisance, possession of methamphetamine, possession of marijuana, and possession of paraphernalia; Seidl moved to suppress the evidence, which the trial court granted; on appeal, the State challenged the suppression order.
The Indiana Court of Appeals reversed and remanded, holding the deputy’s actions did not violate the Fourth Amendment and the consent was valid.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the trial court erred in suppressing the evidence under the Fourth Amendment.	State: officer had legitimate investigative purpose; open view and consent validate search.	Seidl: insufficient reasonable suspicion to enter property; consent was not voluntary.	No; suppression reversed; evidence admissible on remand.

Trimble v. State, 842 N.E.2d 802 (Ind. 2006) (open-view exception and permissible inquiry on property depends on fact-specific open areas)
Hardister v. State, 849 N.E.2d 563 (Ind. 2006) (anonymous tip can justify inquiries; not a basis for suspension of inquiry)
Hayes v. State, 794 N.E.2d 492 (Ind. Ct. App. 2003) (knock-and-talk analysis begins with the door knock)
Redden v. State, 850 N.E.2d 451 (Ind. Ct. App. 2006) (approach to dwelling for questioning does not violate Fourth Amendment absent seizure)
Meyers v. State, 790 N.E.2d 169 (Ind. Ct. App. 2003) (consent to search validity evaluated via totality of circumstances)