Zachary J. Taylor v. State of Indiana, 120 N.E.3d 661

On Jan. 5, 2018 officers responded to anonymous tips of drug activity at Taylor’s apartment and conducted a knock-and-talk at the front door.
Officer Shourds glanced through an inch-wide gap under the blinds on the apartment door window and saw Taylor and a woman (Stokes) with a small glass smoking device.
Officers left to obtain a search warrant; while waiting they contacted and arrested Stokes after she handed over a similar device and alleged pills from Taylor.
Officers obtained a warrant, searched Taylor’s apartment, and found methamphetamine, marijuana, and a digital scale; Taylor was charged with multiple drug offenses and moved to suppress the evidence.
The trial court denied the suppression motion; Taylor was convicted (later pleading to enhance two counts) and sentenced to an aggregate term of 14 years (one year suspended). Taylor appealed, arguing the initial peering was an illegal search under the Fourth Amendment and Article 1, § 11 of the Indiana Constitution.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Officer Shourds’ peering through the gap was a Fourth Amendment search	State: officer was on curtilage conducting a lawful knock-and-talk and observed contraband in open view	Taylor: repositioning body to peer through gap was a warrantless search that violated the Fourth Amendment (Jardines)	Not a search; officer acted within implied license to approach door and observed items in open view
Whether evidence observed from doorway justified warrant application	State: observations gave probable cause and justified obtaining a warrant	Taylor: observations were fruit of an illegal search and thus inadmissible	Observations lawful, supported warrant and evidence admissible
Whether conduct violated Article 1, § 11 of Indiana Constitution	State: conduct was minimally intrusive and reasonable under totality of circumstances	Taylor: state provision affords independent protection making the peering unreasonable	Conduct reasonable under Litchfield balancing (suspicion high; intrusion minimal; law‑enforcement need significant)
Whether trial court abused discretion admitting evidence after suppression denial	State: denial was proper and supported by record	Taylor: admission violated his constitutional rights and affected substantial rights	No abuse of discretion; admission upheld

Florida v. Jardines, 569 U.S. 1 (2013) (use of a drug-sniffing dog on curtilage constituted a Fourth Amendment search; scope of implied license is limited)
Silverman v. United States, 365 U.S. 505 (1961) (articulates sanctity of the home as core Fourth Amendment protection)
Oliver v. United States, 466 U.S. 170 (1984) (defines curtilage as part of the home for Fourth Amendment purposes)
Trimble v. State, 842 N.E.2d 798 (Ind. 2006) (officer approach along visitor’s route for legitimate inquiry does not constitute a search)
Litchfield v. State, 824 N.E.2d 356 (Ind. 2005) (establishes Article 1, § 11 reasonableness test balancing suspicion, intrusion, and law‑enforcement needs)
Mitchell v. State, 745 N.E.2d 775 (Ind. 2001) (explains independent Indiana constitutional analysis under Article 1, § 11)
Justice v. State, 765 N.E.2d 161 (Ind. Ct. App. 2002) (discusses open‑view doctrine and when observations outside protected areas are not searches)