State v. Howie. Police were investigating a stolen property ring in Lexington, KY. Officers received several tips from reliable confidential informants that Howie, who works at a local car wash, also serves as a reseller of stolen property. According to the informants, thieves take their stolen goods to Howie, who buys them for cash. Howie then sells the stolen goods to others for a profit. Officers do not have probable cause at this time to get a search warrant. They decide to go to Howie's home and knock on the door. Police ask Howie if they could come inside and look around. Howie agrees and lets the officers into his home. Officers search around the rooms of the one-floor home but find nothing indicating Howie is in possession of stolen goods.

The officers then go down into the basement. They find a locked storage closet and ask Howie to open it. Howie declines this request and asks the officers to leave immediately. Officers become suspicious and again ask Howie to open the locked closet. Howie again refused and again demands the officers leave. The police then use a crowbar found in Howie's basement to pry open the door. Inside the closet, police find a trove of expensive items, including jewelry, diamonds, watches, and high-end electronics, among other things. Police then arrest Howie for receiving stolen property. Upon arrest, officers search Howie and find a bag of Oxycontin pills and a small amount of cocaine. They search the rest of the basement and find other items later found to be stolen, including two dirt bikes, an antique electric guitar, and some rare books.

Before Howie's trial, he moves to suppress the items found in the closet, items foun