the steps taken by the resident to protect the area from observation by people passing by." In Florida v. Jardines (2013), the Court held, in a 5–4 decision by Justice Antonin Scalia, that the curtilage is protected from police dogs sniffing for marijuana: In Caniglia v. Strom (2021), the Court noted only a "... few permissible invasions of the home and its curtilage. Perhaps most familiar, for example, are searches and seizures pursuant to a valid warrant." The court rejected the standalone doctrine that police "caretaking" duties justify warrantless searches and seizures in the home and its curtilage. First factor: distance In Dunn, the Court said that the location of a barn, being from the home and outside of the fence which completely encircled the home, suggested that it was outside the home's curtilage. In Jardines, the Court found that a porch right in front of a private house is part of the curtilage. Second factor: enclosure by fence In Dunn, the Court said that although the area was surrounded by a fence, the home was surrounded by a different fence and that fence was obviously intended to demark a specific area of land immediately adjacent to the house that is readily identifiable as part and parcel of the house. Third factor: nature of use In Dunn, the Court said that law enforcement officials had evidence that the area was not being used for intimate activities of the home, namely that it was being used to store large amounts of phenylacetic acid (used in the illegal manufacture of drugs) and that it had a very, very strong smell. In Jardines, the Court specifically named a front porch as a prime example of curtilage; even though Girl Scouts or salespersons can knock on the front door, they must leave immediately if there is no answer. Fourth factor: protection from observation In Dunn, the Court said the area was not protected at all from observation by those standing in open fields. Although agents did peer into a barn that was arguably protected by the Fourth Amendment, any such observation from open fields was not protected. (This is the "plain view doctrine", though it is not labeled as such in Dunn.) In Jardines, the Court noted that, while police can stop a person on an open highway, they are prohibited from peering into the windows of a private home from the front porch,