Andre Eugene Sanders v. Commonwealth of Virginia

DECKER, Judge.

Andre Eugene Sanders entered conditional guilty pleas to four counts of drug possession and two counts of assault and battery of a law enforcement officer. On appeal, he contends that the warrantless use of a trained police dog to sniff for illegal drugs outside the door of his motel room on two separate occasions was an unreasonable search that violated his rights under the Fourth Amendment of the United States Constitution. We hold that the use of the drug detection dog in this case was not a search on either occasion. Consequently, we affirm the appellant’s convictions.

I.…