Category: multi-unit dwelling

In U.S. v. Johnson, 148 F.4th 287 (4th Cir. 2025) (summarized here), the U.S. Court of Appeals for the Fourth Circuit recently rejected a Fourth Amendment challenge to a canine sniff at the front door of the defendant’s apartment. My colleagues Jeff Welty and Shea Denning have blogged about the issue of curtilage and multi-unit dwellings like apartment buildings in the past (here, here, and here), but Johnson is a good refresher on those principles. Read on for the details.

Kathy Taft was bludgeoned and raped on March 5, 2010, as she lay in the bedroom of a friends’ home in Raleigh recovering from surgery.  She died four days later.  Raleigh police tracked down her killer, Jason Williford, through what then-police chief Harry Dolan called “gumshoe detective work”:  They collected and tested trash discarded by neighborhood men who refused to provide samples of their DNA.