Atkins v. State
In Atkins v. State, 882 S.W.2d 910 (Tex.App.--Houston 1st Dist. 1994, pet. ref'd), police officers went to a residence to investigate after receiving an anonymous tip that cocaine and heroin were being sold from the residence.
One officer went to the front door where people were seated outside and a second officer walked around the side of the house toward the back door. When the second officer turned the corner he saw the defendant exit the back door. Upon seeing the officer, the defendant dropped two baggies of heroin and re-entered the house.
The officer seized the heroin, followed the defendant inside, and arrested him for possession of heroin. The defendant urged on appeal that because the second officer violated the curtilage by being in the back yard without a warrant, the subsequent seizure of the heroin was unlawful.
The court of appeals held that the evidence supported an inference that the second officer was making a joint initial attempt to contact the inhabitants of the house as sanctioned in Long. Atkins, 882 S.W.2d at 913.