New Case on Curtilage-
US v. Carloss, 13-7082 (10th Cir, 2016)-Carloss lived in a house that had posted "No Trespassing" signs in several locations around his house, including on the front door. Police disregarded the signs and did a knock-and-talk. They were investigating a report that Carloss had a machine gun in violation of his criminal conviction restrictions. Officers were able to obtain consent to enter the residence by Carloss. They asked for consent to search the residence, but were denied, and were asked to leave. While in the residence, the offficers saw drug paraphernalia and they got a search warrant. They searched the home and found multiple meth labs and weapons. Carloss was arrested.
Carloss appealed his conviction claiming that the officers discovered the paraphernalia after they violated the Fourth Amendment by disobeyed the "No Trespassing" signs and knocked on the door. The Court held that under the circumstances presented here, those “No Trespassing” signs would not have conveyed to an objective officer that he could not approach the house and knock on the front door seeking to have a consensual conversation with the occupants. Nor did the officers exceed the implied license to knock on the front door by knocking too long. Just the presence of a “No Trespassing” sign is not alone sufficient to convey to an objective officer, or member of the public, that he cannot go to the front door and knock. Such signs, by themselves, do not have the talismanic quality Carloss attributes to them.