In Florida v. Jardines (2013) U.S. 133 S.Ct. 1409, two detectives, one of whom was a trained canine handler with a drug-sniffing dog, approached the defendant's home. As the dog approached the defendant's front porch, "he apparently sensed one of the odors he had been trained to detect, and began energetically exploring the area for the strongest point source of that odor." (Ibid.) After the dog actively displayed signs of detecting odors associated with drugs, he sat down at the base of the front door, "trained behavior upon discovering the odor's strongest point." (Ibid.) Based on this, the detective applied for and received a warrant to search the defendant's residence. After the warrant was executed, the defendant attempted to flee and was arrested. The detectives found marijuana plants. The defendant was charged with trafficking in cannabis. (Ibid.) The Jardines court reaffirmed a previous United States Supreme Court holding that "there is no doubt that the officers entered the home's curtilage: The front porch is the classic exemplar of an area adjacent to the home and 'to which the activity of home life extends.'" Thereafter, in Jardines, the court analyzed whether the detectives violated the defendant's fourth amendment rights by searching on his front porch. The court acknowledged that the courts "have accordingly recognized that 'the knocker on the front door is treated as an invitation or license to attempt an entry, justifying ingress to the home by solicitors, hawkers and peddlers of all kinds.' This implicit license typically permits the visitor to approach the home by the front path, knock promptly, wait briefly to be received, and then (absent invitation to linger longer) leave. Complying with the terms of that traditional invitation does not require fine-grained legal knowledge; it is generally managed without incident by the Nation's Girl Scouts and trick-or-treaters. Footnote omitted. Thus, a police officer not armed with a warrant may approach a home and knock, precisely because that is 'no more than any private citizen might do.' " ( However, the court noted that by "introducing a trained police dog to explore the area around the home in hopes of discovering incriminating evidence is something else. There is no customary invitation to do that." (Id. at p. 1416.) The court concluded: "The government's use of trained police dogs to investigate the home and its immediate surroundings is a 'search' within the meaning of the Fourth Amendment." (Id. at pp. 1417-1418.)