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MN: Landlord's complaints of high traffic to an apartment was RS for a dog sniff in the common hallway

By John Wesley Hall, Jr.

Under Minnesota's rule that a drug dog in a common hallway requires reasonable suspicion, an apartment manager's report of "high" traffic to an apartment was sufficient, considering the admittedly low standard of reasonable suspicion. State v. Baumann, 2009 Minn. App. LEXIS 20 (January 13, 2009): Here, a property manager thought that the level of short-term traffic coming to and leaving from Baumann's apartment was odd and suspicious. Inferentially, the manager of an apartment complex would have some degree of duty to be concerned about the use of the property since illegal activities on the premises could be problematic for the property owner and perhaps jeopardize rentals. So, the manager reported the facts she observed to a narcotics investigator...continue to full post

Full post as published by Fourth Amendment on February 12, 2009 (boomark / email).