State v. Ruiz, 2021 UT App 94 (Sept. 2, 2021)

Odin, a drug detection K-9, leapt through a partially open window into the car during a drug sniff of the exterior of the car. Applying the test articulated by the Tenth Circuit, the court held Odin’s entry was lawful. Under that test, K-9s’ entries into cars during an exterior sniff have been held lawful where “(1) the dog’s leap into the car was instinctual rather than orchestrated and (2) the officers did not ask the driver to open the point of entry, such as a hatchback or window, used by the dog.”