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97 Minn. L. Rev. 337 (2012-2013)
Warrantless Search Cases Are Really All the Same

handle is hein.journals/mnlr97 and id is 347 raw text is: Note Warrantless Search Cases Are Really All the Same Will Stancil* Reading Fourth Amendment case law is a lot like watching a Law & Order marathon: by the second or third hour, all the storylines start to repeat themselves. Real-life police investiga- tions, like police procedurals, tend to recycle and interchange key elements. A police dog sniffs a car;' a radio beeper monitors a home.' A police dog sniffs a home;' a radio beeper monitors a car.4 As a result, Fourth Amendment cases have a certain mix- and-match quality, and after a while, careful observers might begin to notice that the old scenarios and new scenarios are built out of many of the same pieces. But Fourth Amendment cases often share another trait with cop shows: twist endings. The writers are always finding new ways to surprise, and even a minor change in the facts can flip established rules on their heads, generating outcomes that seem contrary to decades of * JD/MPP Candidate 2013, University of Minnesota; MA 2008, Queens University Belfast; BS 2007, Wake Forest University. Thanks to Professor Barry Feld for his work as this Note's advisor, Professor Richard Frase for get- ting excited enough about the original idea that it did not end up in the trash heap, and to the editors and staff of Minnesota Law Review for their help bringing the whole thing to publication. Especially Christina MeSparron, Ja- mie Ling, Carl Engstrom, Dan Iden, and whoever left that bottle of top-shelf whiskey in the freezer (probably Carl Engstrom, again). Additionally, the au- thor would like to thank Jim Morrison (not that Jim Morrison), his parents (for pretending they enjoyed reading this thing), and Hero Captain Chesley Sully Sullenberger. The author believes that legally-actionable imitation is the sincerest form of flattery, and therefore disclaims all copyright in this work. He would, however, appreciate attribution for any borrowed bits, partic- ularly if you are famous. 1. See Illinois v. Caballes, 543 U.S. 405, 406 (2005); City of Indianapolis v. Edmond, 531 U.S. 32, 34-35 (2000). 2. See United States v. Karo, 468 U.S. 705, 708-10 (1984). 3. See Jardines v. State, 73 So. 3d 34, 35 (Fla. 2011), cert. granted, 132 S. Ct. 995 (2012). 4. See United States v. Knotts, 460 U.S. 276, 277-78 (1983). 337

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