California, United States of America
The following excerpt is from People v. Pullman, H043168 (Cal. App. 2017):
Defendant's moving papers did not address whether, in the event the officers' decision to freeze the residence was supported by probable cause, the security sweep was reasonable. When asked by the trial court what the prosecution needed to show to establish a lawful security sweep, defendant argued that "a quick run around the back to see if somebody is back there is one thing, but observations that lead to probable cause ... based on specialized training" rendered the sweep unlawful under Florida v. Jardines (2013) 133 S.Ct 1409.
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