Missouri Court of Appeals, Western District / May 28, 2019
State of Missouri vs. Leland Dwayne Daggett
Leland Daggett appealed his convictions for drug and firearm offenses, arguing the trial court erred in denying his motion to suppress evidence seized from a garden. Daggett contended the garden was outside the scope of the search warrant because it was not part of the dwelling's curtilage. The appellate court affirmed the convictions, holding that the garden, located 20-30 yards from the home in a rural area and used for domestic gardening, was indeed within the curtilage, making the search authorized by the warrant.