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Case Clips

Published by the Indiana Office of Court Services

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Ocampo v. State, No. 24A-CR-2785, __ N.E.3d __ (Ind. Ct. App., Aug. 29, 2025).

September 2, 2025 Filed Under: Uncategorized Tagged With: Appeals, M. DeBoer

The legality of a K9’s interior sniff of a vehicle before probable cause has been established to conduct a search is governed by the “instinctive entry rule,” under which a K9’s instinctive entry into a vehicle does not implicate the Fourth Amendment so long as it is not directed, encouraged, or facilitated by officers.

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Case Clips is a weekly publication of the Indiana Office of Court Services featuring appellate opinions curated by IOCS staff for Indiana judges.

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