My Honors 300: Writing in the Law students from the last two semesters will find this interesting. Remember that Florida v. Jardines involved a drug sniffing dog on the porch/curtilage of a home. Remember also that the dog and its handler stayed on the porch for some time, longer than someone who knocks and leaves. Well, the Court of Appeals of Indiana (a state court) in J.K. v. State just relied on Jardines to rule that officers need to knock and leave. That is, police officers have an implied invitation to approach a door and to knock on it. They can’t, well, do the following:
The officers surrounded J.K.’s residence around one o’clock in the morning and repeatedly knocked on the door for over forty-five minutes. During that span of time, the officers peered through the windows and continuously yelled into the house demanding that an occupant answer the door.
You can read the opinion at the link above or read a summary on The Volokh Conspiracy.