Court of Appeals of Indiana
Courtney Elizabeth Crabtree v. State of Indiana
21A-CR-2752
Criminal. Affirms the denial of Courtney Elizabeth Crabtree’s motion to suppress evidence found in her hotel room after a dog sniff. Finds the reasoning in Hoop v. State does not extend to these circumstances, so reasonable suspicion is not required here. Also finds that under the comprehensive three-factor balancing test in Litchfield v. State, the dog sniff was reasonable. Finally, finds that while the other evidence used to procure the search warrant was illegally obtained, the dog sniff and other evidence provided sufficient legally obtained information to support the issuance of a search warrant. Judge Elizabeth Tavitas concurs in result with separate opinion.