This case had two issues. The first was whether probable cause existed for the issuance of a tracking warrant. The second was whether the ATF agents violated Coleman’s Fourth Amendment rights when they first entered the condominium parking lot and then again when they went onto his driveway (which Coleman argues was his curtilage).
The court held that probable cause existed to support the tracking warrant. The court then applied the four Dunn Factors from United States v. Dunn, 480 U.S. 294, 301 (1987) to determine the driveway to his garage (which was actually shared with another condo) was not in the curtilage.
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