P. v. Meves
Appellant Rocky Reno Meves contends the trial court erred in denying his motion to suppress evidence. Specifically, Meves asserts (1) the deputy sheriff was within the curtilage of his (Meves’s) home, which was constitutionally protected; (2) the deputy unreasonably was within the curtilage; and (3) the subsequent search and seizure was unconstitutional. The trial court’s factual finding that the deputy was not within the curtilage was supported by substantial evidence. Regardless, mere presence within the curtilage of a residence does not constitute an unlawful entry and unconstitutional search. The deputy reasonably was in the location from where he made his observations. We will affirm the trial court’s denial of the suppression motion.
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