A warrantless blood draw is permissible when: 1) the blood is taken to obtain evidence of intoxication from a person lawfully arrested; 2) there is a clear indication evidence of intoxication will be produced; 3) the method used is reasonable and performed in a reasonable manner; and 4) the arrestee presents no reasonable objection. State v. Thorstad, 2000 WI App 199, 238 Wis. 2d 666, 618 N.W.2d 240, 99-1765. But see Birchfield v. North Dakota, 579 U.S. 438, 136 S. Ct. 2160, 195 L. Ed. 2d 560 (2016). That a driver stopped at a stop sign for a few seconds longer than normal, that it was late in the evening, and that there was little traffic did not give rise to a reasonable suspicion that the driver was committing an unlawful act. State v. Fields, 2000 WI App 218, 239 Wis. 2d 38, 619 N.W.2d 279, 00-0694. A warrantless entry need not be subjectively motivated solely by a perceived need to render aid and assistance in order for the “emergency doctrine” to apply. A dual motivation of investigating a potential crime and rendering aid and assistance may be present. State v. Rome, 2000 WI App 243, 239 Wis. 2d 491, 620 N.W.2d 225, 00-0796. Whether a search is a probation search, which may be conducted without a warrant, or a police search, which may not, is a question of constitutional fact to be reviewed in a two-step review of historical and constitutional fact. A determination of reasonableness of the search must also be made. A search is reasonable if the probation officer has reasonable grounds to believe that the probationer has contraband. Cooperation with police officers does not change a probation search into a police search. State v. Hajicek, 2001 WI 3, 240 Wis. 2d 349, 620 N.W.2d 781, 98-3485. In light of the reduced expectation of privacy that applies to property in an automobile, the search of a vehicle passenger’s jacket based upon the driver’s consent to the search of the vehicle was reasonable. State v. Matejka, 2001 WI 5, 241 Wis. 2d 52, 621 N.W.2d 891, 99-0070. Before the government may invade the sanctity of the home, it must demonstrate exigent circumstances that overcome the presumption of unreasonableness that attaches to all warrantless home entries. Reluctance to find an exigency is especially appropriate when the underlying offense for which there is probable cause to arrest is relatively minor. State v. Kryzaniak, 2001 WI App 44, 241 Wis. 2d 358, 624 N.W.2d 389, 00-1149. Under J.L, 529 U.S. 266 (2000), an anonymous tip giving rise to reasonable suspicion must bear indicia of reliability. That the tipster’s anonymity is placed at risk indicates that the informant is genuinely concerned and not a fallacious prankster. Corroborated aspects of the tip also lend credibility. The corroborated actions of the suspect must be inherently criminal in and of themselves. State v. Williams, 2001 WI 21, 241 Wis. 2d 631, 623 N.W.2d 106, 96-1821. An anonymous tip regarding erratic driving from another driver calling from a cell phone contained sufficient indicia of reliability to justify an investigative stop when the informant was exposed to possible identification, and therefore possible arrest if the tip proved false; the tip reported contemporaneous and verifiable observations regarding the driving, location, and vehicle; and the officer verified many of the details in the tip. That the tip reasonably suggested intoxicated driving created an exigency strongly in favor of immediate police investigation without the necessity that the officer personally observe erratic driving. State v. Rutzinski, 2001 WI 22, 241 Wis. 2d 729, 623 N.W.2d 516, 98-3541. When a caller identifies himself or herself by name, placing the caller’s anonymity at risk, and the totality of the circumstances establishes a reasonable suspicion that criminal activity may be afoot, the police may execute a lawful investigative stop. Whether the caller gave correct identifying information or the police ultimately could have verified the information, the caller, by providing the information, risked that the caller’s identity would be discovered and cannot be considered anonymous. State v. Sisk, 2001 WI App 182, 247 Wis. 2d 443, 634 N.W.2d 877, 00-2614. The state constitution does not provide greater protection under the automobile exception for warrantless searches than the 4th amendment. The warrantless search of a vehicle is allowed when there is probable cause to search the vehicle and the vehicle is mobile. The exception apples to vehicles that are not in public places. There is no requirement that obtaining a warrant be impracticable. State v. Marquardt, 2001 WI App 219, 247 Wis. 2d 765, 635 N.W.2d 188, 01-0065. Whether exigent circumstances existed justifying a warrantless entry to prevent destruction of evidence after the defendant saw, and retreated from, a plain-clothes officer was not a question of whether the defendant knew that the detective was a police officer, but whether it was reasonable for the officer to believe that the officer had been identified and that the suspect would destroy evidence as a consequence. State v. Garrett, 2001 WI App 240, 248 Wis. 2d 61, 635 N.W.2d 615, 00-3183. For the warrantless search of an area made incident to the making of an arrest to be justified as a protective sweep to protect the safety of police officers where the area searched is not in the immediate vicinity of where the arrest is made, there must be articulable facts that would warrant a reasonably prudent officer to believe that the area harbors an individual posing a danger to the officers. State v. Garrett, 2001 WI App 240, 248 Wis. 2d 61, 635 N.W.2d 615, 00-3183. The need to transport a person in a police vehicle is not an exigency that justifies a search for weapons. More specific and articulable facts must be shown to support a Terry, 392 U.S. 1 (1968), frisk. While a routine pat-down of a person before a police officer places the person in a squad car is wholly reasonable, evidence gleaned from the search will only be admissible if there are particularized issues of safety concerns about the defendant. State v. Hart, 2001 WI App 283, 249 Wis. 2d 329, 639 N.W.2d 213, 00-1444. Although no traffic violation occurred, a traffic stop to make contact with the defendant was reasonable when police had reasonable suspicion that the defendant had previously been involved in a crime, and the defendant had intentionally avoided police attempts to engage the defendant in voluntary conversation. State v. Olson, 2001 WI App 284, 249 Wis. 2d 391, 639 N.W.2d 207, 00-3383. A warrantless blood draw by a physician in a jail setting may be unreasonable if it invites an unjustified element of personal risk of pain and infection. Absent evidence of those risks, a blood draw under those circumstances was reasonable. State v. Daggett, 2002 WI App 32, 250 Wis. 2d 112, 640 N.W.2d 546, 01-1417. Terry, 392 U.S. 1 (1968), applies to confrontations between the police and citizens in public places only. For private residences and hotels, in the absence of a warrant, the police must have probable cause and exigent circumstances or consent to justify an entry. Reasonable suspicion is not a prerequisite to an officer’s seeking consent to enter a private dwelling. If the police have lawfully entered a dwelling with valid consent and have a reasonable suspicion that a suspect is armed, a Terry pat down for weapons is permissible. State v. Stout, 2002 WI App 41, 250 Wis. 2d 768, 641 N.W.2d 474, 01-0904. A warrantless search of a home is presumptively unreasonable, but exigent circumstances that militate against delay in getting a warrant can justify immediate entry and search. Whether the officers acted reasonably in entering the house without a warrant is measured against what a reasonable police officer would reasonably believe under the circumstances. State v. Londo, 2002 WI App 90, 252 Wis. 2d 731, 643 N.W.2d 869, 01-1015. Canine sniffs are not searches within the meaning of the 4th amendment, and police are not required to have probable cause or reasonable suspicion before walking a dog around a vehicle for the purpose of detecting drugs in the vehicle’s interior. A dog’s alert on an object provides probable cause to search that object, provided that the dog is trained in narcotics detection and has demonstrated a sufficient level of reliability in detecting drugs in the past and the officer with the dog is familiar with how it reacts when it smells contraband. State v. Miller, 2002 WI App 150, 256 Wis. 2d 80, 647 N.W.2d 348, 01-1993. But see State v. Campbell, 2024 WI App 17, 411 Wis. 2d 439, 5 N.W.3d 870, 20-1813. Evidence from a warrantless nonconsensual blood draw is admissible when: 1) the blood is drawn to obtain evidence of intoxication from a person lawfully arrested for drunk-driving; 2) there is a clear indication that the blood draw will produce evidence of intoxication; 3) the method used to take the blood sample is reasonable and is performed reasonably; and 4) the arrestee presents no reasonable objection to the blood draw. In the absence of an arrest, probable cause to believe blood currently contains evidence of a drunk-driving-related violation satisfies the first and second prongs. State v. Erickson, 2003 WI App 43, 260 Wis. 2d 279, 659 N.W.2d 407, 01-3367. But see Birchfield v. North Dakota, 579 U.S. 438, 136 S. Ct. 2160, 195 L. Ed. 2d 560 (2016). When an unlocked vehicle was not: 1) involved in an accident; 2) interrupting the flow of traffic; 3) disabled or damaged; 4) violating parking ordinances; or 5) in any way jeopardizing the public safety or the efficient movement of vehicular traffic, it was unreasonable to impound and tow the vehicle to ensure that the vehicle and any property inside it would not be stolen when there were reasonable alternatives to protect the vehicle. Evidence seized in an “inventory search” of the vehicle was inadmissible. State v. Clark, 2003 WI App 121, 265 Wis. 2d 557, 666 N.W.2d 112, 02-2195. Before the government may invade the sanctity of the home without a warrant, the government must demonstrate not only probable cause but also exigent circumstances that overcome the presumption of unreasonableness. When a police officer placed the officer’s foot in a doorway to prevent the defendant from closing the door, the act constituted an entry into the home. A warrantless home arrest cannot be upheld simply because evidence of the suspect’s blood alcohol level might have dissipated while the police obtained a warrant. State v. Larson, 2003 WI App 150, 266 Wis. 2d 236, 668 N.W.2d 338, 02-2881. To perform a protective search for weapons, an officer must have reasonable suspicion that an individual may be armed and dangerous. A court may consider an officer’s belief that the officer’s or another’s safety is threatened in finding reasonable suspicion, but such a belief is not a prerequisite to a valid search. There is no per se rule justifying a search any time an individual places the individual’s hands in the individual’s pockets contrary to police orders. The individual’s hand movements must be considered under the totality of the circumstances of the case. State v. Kyles, 2004 WI 15, 269 Wis. 2d 1, 675 N.W.2d 449, 02-1540. The propriety of a warrantless search of a person’s garbage outside the person’s home comes under a two-part test: 1) whether the person by the person’s conduct has exhibited an actual, subjective expectation of privacy; and 2) whether that expectation is justifiable in that it is one that society will recognize as reasonable. Consideration of curtilage or open fields appropriately falls within an expectation-of-privacy analysis and is not a separate factor. In this case, the defendant did not have a reasonable expectation of privacy in garbage placed in a dumpster not set out for collection located down a private driveway marked “Private Property.” State v. Sigarroa, 2004 WI App 16, 269 Wis. 2d 234, 674 N.W.2d 894, 03-0703. When the police are lawfully on the suspect’s premises by virtue of a valid search warrant, they may make a warrantless arrest of the suspect prior to the search if the arrest is supported by probable cause. State v. Cash, 2004 WI App 63, 271 Wis. 2d 451, 677 N.W.2d 709, 03-1614. A law enforcement officer acted reasonably when during a routine traffic stop the officer requested the passengers, as well as the driver, to exit the vehicle and individually asked them questions outside the scope of the initial traffic stop after the officer had become aware of specific and articulable facts giving rise to the reasonable suspicion that a crime had been, was being, or was about to be committed. State v. Malone, 2004 WI 108, 274 Wis. 2d 540, 683 N.W.2d 1, 02-2216. Whether a warrantless home entry is justified based on the need to render assistance or prevent harm is judged by an objective test of whether a police officer under the circumstances known to the officer at the time of entry reasonably believes that delay in procuring a warrant would gravely endanger life. In addition to the circumstances known to the police at the time of entry, a court may consider the subjective beliefs of police officers involved, but only insofar as such evidence assists the court in determining objective reasonableness. State v. Leutenegger, 2004 WI App 127, 275 Wis. 2d 512, 685 N.W.2d 536, 03-0133. Although a known citizen informer did not observe the defendant drive the defendant’s truck in a manner consistent with someone who was under the influence of an intoxicant, the tip was reliable when it was based on the informer’s first-hand observation that the defendant was drunk and was independently verified by the arresting officer. State v. Powers, 2004 WI App 143, 275 Wis. 2d 456, 685 N.W.2d 869, 03-2450.