People v. Kofron

(Court opinion corrected 9/12/14.) Defendant, who was at least an overnight gust in neighbor's home, had reasonable expectation of privacy in private area of backyard, from which chemical materials near trash can were seized. In any "knock and talk" where officers approach entrance to home to make investigative inquiry and to attempt to obtain consent to search, there is no legitimate rationale for deploying multiple police officers to cover multiple entrances to a home in effort to prevent citizens from "escaping" from "consensual encounter" with police. Court properly granted motion to suppress evidence. (WELCH and SCHWARM, concurring.)