A police officer’s act of opening a vehicle’s passenger door in order to effectively communicate with a driver otherwise inaccessible due to the malfunctioning driver’s door and window when the defendant appeared to be cooperating and moving toward the passenger seat, and seemed to be trying to open the passenger door, did not constitute an unreasonable search. The officer’s actions, viewed objectively, would warrant a person of reasonable caution to believe the action taken was appropriate. State v. Smith, 2018 WI 2, 379 Wis. 2d 86, 905 N.W.2d 353, 15-0756. Despite the defendant passing field sobriety tests and the officer apparently concluding that the defendant was not impaired due to alcohol, the officer, quite reasonably, believed there was “something else going on,” though the officer did not know if it was a medical issue or a drug issue. From the totality of the circumstances, a reasonable inference of wrongful conduct—that the defendant had driven while under the influence of a drug or drugs—could be objectively discerned, and thus the officer had the right to continue the temporary detention of the defendant for further investigation. State v. Rose, 2018 WI App 5, 379 Wis. 2d 664, 907 N.W.2d 463, 16-2257. Under Payton, 445 U.S. 573 (1980), police may enter a residence pursuant to an arrest warrant if the facts and circumstances present the police with a reasonable belief that: 1) the subject of the arrest warrant resides in the home; and 2) the subject of the arrest warrant is present in the home at the time entry is effected. State v. Delap, 2018 WI 64, 382 Wis. 2d 92, 913 N.W.2d 175, 16-2196. A search occurs when a convicted recidivist sex offender who has completed the offender’s sentence is required to attach a monitoring device to the offender’s body to track the offender’s movements. The reasonableness of a search depends upon the totality of the circumstances, including the nature and purpose of the search and the extent to which the search intrudes upon reasonable privacy expectations. Under the totality of the circumstances, given the diminished nature of a defendant’s privacy interest and the state’s particularly strong interest in reducing recidivism through the information collected by the tracking device, the global positioning system tracking requirement for convicted sex offenders is reasonable under the 4th amendment. Kaufman v. Walker, 2018 WI App 37, 382 Wis. 2d 774, 915 N.W.2d 193, 17-0085. The 4th amendment’s special needs doctrine applies to s. 301.48. The global positioning system (GPS) tracking program effectively serves the recognized special needs of deterring future crimes and gathering information needed to solve them. The state’s interest in accomplishing these special needs in the context of sex crimes outweighs sex offenders’ diminished privacy expectations. Kaufman v. Walker, 2018 WI App 37, 382 Wis. 2d 774, 915 N.W.2d 193, 17-0085. Under Birchfield, 579 U.S. 438 (2016), it is impermissible to impose criminal penalties for refusing to submit to a warrantless blood draw. A lengthier jail sentence is a criminal penalty. Therefore, the circuit court in this case violated Birchfield by explicitly subjecting the defendant to a more severe criminal penalty because the defendant refused to provide a blood sample absent a warrant. State v. Dalton, 2018 WI 85, 383 Wis. 2d 147, 914 N.W.2d 120, 16-2483. The expectation of privacy in digital files is governed by the same standards as the expectation of privacy in physical property. There is no reasonable expectation of privacy in digital files that are publicly shared on a peer-to-peer network, including when law enforcement uses non-publicly available softwear and geolocation services based on a publicly available internet protocol (IP) address to discover the files and locate the defendant. State v. Baric, 2018 WI App 63, 384 Wis. 2d 359, 919 N.W.2d 221, 17-0185. Whether consent is verbal or inferred from one’s actions, consent must be unequivocal and specific. Leading an officer to the threshold of an apartment and then entering the apartment and closing the door does not imply consent for the officer to enter the apartment. The standard for measuring the scope of a suspect’s consent under the 4th amendment is that of objective reasonableness—what the typical reasonable person would have understood by the exchange between the officer and the suspect. State v. Reed, 2018 WI 109, 384 Wis. 2d 469, 920 N.W.2d 56, 16-1609. Generalized concerns for safety and risk of flight are not enough to give rise to exigent circumstances. The test is whether there are objective facts known to the officer that would reasonably lead the officer to believe that the delay caused by obtaining a warrant would gravely endanger life or greatly enhance the likelihood of the subject’s escape. State v. Reed, 2018 WI 109, 384 Wis. 2d 469, 920 N.W.2d 56, 16-1609. The 4th amendment tolerates certain investigations that are outside the scope of the mission of a traffic stop, so long as the investigations do not measurably extend the duration of the stop. When the officer questioned the defendant on whether the defendant had a valid concealed carry permit, although the questioning and a permit check were outside the mission of the traffic stop, they did not violate the 4th amendment because they did not measurably extend the duration of the stop and were conducted concurrently with mission-related activities. State v. Wright, 2019 WI 45, 386 Wis. 2d 495, 926 N.W.2d 157, 17-2006. See also State v. Brown, 2020 WI 63, 392 Wis. 2d 454, 945 N.W.2d 584, 17-0774. An anonymous informant is considered reliable if police are able to corroborate details in the informant’s tip. In this case, the record contained no information indicating the informant’s identity or whether the informant had provided reliable information to police in the past, but, because the tips were corroborated, the court did not discount them entirely in its analysis. Accordingly, the corroborated tips of the unnamed informant in this case could be considered in the analysis of the totality of the circumstances, giving them such weight as they were due. State v. Anderson, 2019 WI 97, 389 Wis. 2d 106, 935 N.W.2d 285, 17-1104. In this case, the immediate and continuous pursuit was a hot pursuit satisfying the 4th amendment exception to the warrant requirement. The measured speed at which the pursuit occurred in no way lessened its “hot” nature. State v. Ionescu, 2019 WI App 68, 389 Wis. 2d 586, 937 N.W.2d 90, 18-1620. The reasonableness approach, and not the categorical approach, is the correct interpretation of Gant, 556 U.S. 332 (2009). When the totality of the circumstances objectively demonstrated that the officer had reasonable suspicion that a bag in the passenger compartment of the vehicle might contain relevant evidence of operating while intoxicated (OWI), the search was permissible under the 4th amendment. State v. Coffee, 2020 WI 53, 391 Wis. 2d 831, 943 N.W.2d 845, 18-1209. In this case, the deputies were not performing a bona fide community caretaker function when they seized the defendant’s vehicle without a warrant. The defendant was parked on the side of a road after having been stopped for speeding, was alone in the vehicle, and had been driving with a suspended operator’s license. Although the defendant told the deputies who were issuing the traffic citations that the defendant could have a licensed driver retrieve the vehicle, the deputies told the defendant department policy required them to take the vehicle to an impound lot. A standardized policy may provide some evidence that the police performed their community caretaker role reasonably, but it cannot establish the predicate—that they were acting as community caretakers. Because the seizure in this case violated the 4th amendment, so did the ensuing inventory search. State v. Brooks, 2020 WI 60, 392 Wis. 2d 402, 944 N.W.2d 832, 18-1774. The U.S. Supreme Court in Mitchell, 588 U.S. ___, 139 S. Ct. 2525 (2019), indicated that a court’s exigent-circumstances analysis should consider whether law enforcement could have taken steps en route to a medical facility without significantly increasing the delay in procuring the blood sample. A court is not at liberty to begin the exigency analysis for a warrantless blood draw at a point following a suspect’s refusal to provide a blood sample when the U.S. Supreme Court has indicated the analysis begins earlier. State v. Hay, 2020 WI App 35, 392 Wis. 2d 845, 946 N.W.2d 190, 18-2240. Following Mitchell, 588 U.S. ___, 139 S. Ct. 2525 (2019), the four factors that the state bears the burden to show that exigent circumstances justified a warrantless blood draw are: 1) law enforcement has probable cause to believe that the driver has committed a “drunk-driving offense”; 2) the driver is, at pertinent times, unconscious or in a stupor; 3) the driver’s unconscious state or stupor requires that the driver be taken to a hospital or similar facility; and 4) the driver is taken to the hospital or similar facility before law enforcement has a “reasonable opportunity” to administer a standard evidentiary breath test. The burden is on the defendant to show that the defendant’s blood would not have been drawn if police had not been seeking blood alcohol concentration information and to show that law enforcement could not have reasonably judged that a warrant application would interfere with other pressing needs or duties. State v. Richards, 2020 WI App 48, 393 Wis. 2d 772, 948 N.W.2d 359, 17-0043. See also State v. Mitchell, 2022 WI App 31, 404 Wis. 2d 103, 978 N.W.2d 231, 19-1942. Because the natural dissipation of alcohol over time presents a risk that evidence will be destroyed, the passage of time may help support an exigent circumstances determination in a given case. Here, there had already been a significant delay, which occurred through no fault of the police. An objectively reasonable officer would have been concerned that additional delay to obtain a warrant, beyond the five hours that had already elapsed, would have further undermined the probative value of a test, possibly even rendering it inadmissible if an expert was not able to support its probative value. State v. Dieter, 2020 WI App 49, 393 Wis. 2d 796, 948 N.W.2d 431, 18-2269. The reasonable suspicion test for executing a traffic stop is not an exercise in evaluating individual details in isolation. It is the whole picture, evaluated together, that serves as the proper analytical framework. State v. Genous, 2021 WI 50, 397 Wis. 2d 293, 961 N.W.2d 41, 19-0435. A reasonable person being repetitively questioned while the officer retains the person’s driver’s license would not feel free to drive away and thereby terminate the encounter. In this case, it was the officer’s conduct of retaining the driver’s licenses, while repeatedly asking questions that the defendant and the passenger had already answered, that coerced the defendant to remain in the jurisdiction. Also, the officer’s questioning was intended to require them to remain in the jurisdiction so that time would pass and a drug-sniff dog would appear to sniff for drugs. Accordingly, the defendant was seized during the second round of repetitive questions while the officer retained the defendant’s driver’s license. State v. VanBeek, 2021 WI 51, 397 Wis. 2d 311, 960 N.W.2d 32, 19-0447. Although the time it takes to ask a question is measurable, the fact that an inquiry is made does not, in and of itself, create the type of unreasonable burden to make an extension of a traffic stop unlawful for 4th amendment purposes. That notion is true whether the question occurs in the “middle” of a stop versus at the very end of one. State v. Crone, 2021 WI App 29, 398 Wis. 2d 244, 961 N.W.2d 97, 18-1764. Checking for bond conditions is not an ordinary inquiry incidental to the mission of a traffic stop. Officers may check bond conditions while simultaneously performing other mission-related tasks, but they may not prolong a stop to inquire into a motorist’s bond conditions without reasonable suspicion that the motorist is violating a bond condition. State v. Davis, 2021 WI App 65, 399 Wis. 2d 354, 965 N.W.2d 84, 20-0731. The supreme court has stated that, based on the reasonable suspicion of the offense of operating while intoxicated, an officer may request a driver to perform various field sobriety tests. That statement does not require that an officer observe facts suggesting intoxication when administering field sobriety tests upon reasonable suspicion of operating with a prohibited alcohol concentration. State v. Adell, 2021 WI App 72, 399 Wis. 2d 399, 966 N.W.2d 115, 20-2135. If, during a valid traffic stop, an officer becomes aware of additional suspicious factors that are sufficient to give rise to an articulable suspicion that the person has committed or is committing an offense or offenses separate and distinct from the acts that prompted the officer’s intervention in the first place, the stop may be extended and a new investigation begun. The validity of the extension is tested in the same manner, and under the same criteria, as the initial stop. In this case, the deputy lawfully extended the traffic stop because the totality of the facts as they unfolded established reasonable suspicion to investigate the offense of operating with a prohibited alcohol concentration, and the deputy lawfully administered field sobriety tests in furtherance of that investigation because those tests would be likely to support or dispel the deputy’s suspicion. State v. Adell, 2021 WI App 72, 399 Wis. 2d 399, 966 N.W.2d 115, 20-2135. The emergency aid exception to the warrant requirement does not require that officers personally observe indications of an ongoing medical emergency. Reliable and corroborated information from an informant may justify a warrantless search of a home under the emergency aid exception. State v. Ware, 2021 WI App 83, 400 Wis. 2d 118, 968 N.W.2d 752, 20-1559. Courts apply a two-part test in determining whether the emergency aid exception applies. Under the totality of the circumstances, a reasonable person would believe that: 1) there is an immediate need to provide aid or assistance to a person due to actual or threatened physical injury; and 2) immediate entry into an area in which a person has a reasonable expectation of privacy is necessary in order to provide that aid or assistance. State v. Ware, 2021 WI App 83, 400 Wis. 2d 118, 968 N.W.2d 752, 20-1559. The results of a hospital blood test that were subpoenaed after the circuit court suppressed evidence from an unlawful blood draw were admissible under the independent source doctrine. The state’s decision to subpoena the hospital for the defendant’s medical records was not prompted by the deputy’s unlawful conduct because the state had reasonable grounds to suspect the defendant of operating while intoxicated prior to the deputy’s warrantless blood draw. The fact that the state subpoenaed those records only after the circuit court suppressed the deputy’s unlawful blood draw did not change the independent nature of the state’s suspicions that the defendant’s blood-alcohol concentration was over the legal limit. Furthermore, the evidence discovered through the state’s subpoena—the hospital’s diagnostic blood test—was untainted by the deputy’s unlawful conduct, thus suppressing it would not serve the exclusionary rule’s purpose. State v. Van Linn, 2022 WI 16, 401 Wis. 2d 1, 971 N.W.2d 478, 19-1317. Police lack reasonable suspicion to justify an investigatory stop if there are not specific, articulable facts, and all rational inferences that may be drawn from those facts, to suspect that criminal activity is afoot. When a deputy observed an individual wearing black clothing and riding a bicycle, crossing and then leaving publicly-accessible school grounds in the early hours of a Sunday morning, while the state was under the Department of Health Services’ Safer at Home order due to the COVID-19 pandemic, the state failed to clear the “low bar” of reasonable suspicion and instead relied on what could be described, at most, as “a mere hunch” of the deputy. That is, the evidence regarding events leading up to the stop failed to establish articulable facts and rational inferences from those facts that could have led a reasonable officer to suspect that the defendant had engaged in criminal activity, was currently doing so, or was about to do so. State v. Meddaugh, 2022 WI App 12, 401 Wis. 2d 134, 972 N.W.2d 181, 21-0939. Lacking a warrant or exigent circumstances, officers had no lawful basis to open the defendant’s hotel room door—even just the few inches they initially could—and peer inside or even speak to the defendant through that opening. Absent the officer’s unlawful opening of the defendant’s door and utilization of that opening, there was no reason to believe the defendant ever would have even gotten out of bed much less been in a position to visibly turn away from the officers at the door. Under the facts of this case, the officers’ forced entry into the room—leading to the discovery of the gun—cannot be legitimized by the defendant’s turning away from the door because the officer’s observation of that action was not lawfully grounded. State v. Bourgeois, 2022 WI App 18, 401 Wis. 2d 489, 973 N.W.2d 818, 20-1808.