The following excerpt is from USA v. Maggio, 228 F.3d 1080 (9th Cir. 2000):
50. Cf. United States v. Concepcion , 942 F.2d 1170, 1173 (7th Cir. 1991) (finding no Fourth Amendment violation where police inserted keys into lock of apartment door because "the privacy interest [in the keyhole] is so small that the officers do not need probable cause to inspect it"); United States v. DeBardeleben, 740 F.2d 440. 445 (6th Cir. 1984) (upholding insertion of a key into a car door lock because it was "merely a minimal intrusion, justified by a `founded suspicion' and by the legitimate crime investigation").
50. Cf. United States v. Concepcion , 942 F.2d 1170, 1173 (7th Cir. 1991) (finding no Fourth Amendment violation where police inserted keys into lock of apartment door because "the privacy interest [in the keyhole] is so small that the officers do not need probable cause to inspect it"); United States v. DeBardeleben, 740 F.2d 440. 445 (6th Cir. 1984) (upholding insertion of a key into a car door lock because it was "merely a minimal intrusion, justified by a `founded suspicion' and by the legitimate crime investigation").
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