ABSTRACT
Although Place does not concern a canine sniff carried out on private property and directed at the closed door of a private area, we believe that the majority view of the United States Supreme Court would be that the canine sniff in the present case would not constitute a search. We reach this conclusion because of the importance the federal court attaches to the lack of intrusiveness of a canine sniff; because the disclosure of information as a result of the sniff is extremely limited; because the consequent embarrassment and inconvenience is minimal; and because although the appellant’s parcels were not located in a public place, they were located near enough a public hallway that a trained dog, standing in that hallway could identify the odor of marijuana.
