home may be unlawful depending upon the nature of the area in question. See, e.g., United States v. Struckman, 603 F.3d 731, 739 (9th Cir. 2010) (recognizing that curtilage garners the home's protection against warrantless entry for arrest); United States v. Brown, 510 F.3d 57, 64 (1st Cir. 2007) (conducting curtilage analysis with respect to driveway and noting the principles applicable to driveways when determining whether resident was arrested in violation of protection against warrantless entry); State v. Lewis, 675 N.W.2d 516, 523-26 (Iowa 2004) (conducting curtilage analysis for an unsecured driveway in determining whether defendant was arrested in violation of Fourth Amendment's protection against warrantless entry); State v. Karle, 759 N.E.2d 815, 819-20 (Ohio Ct. App. 2001) (<HOLDING>); Jefferson v. Commonwealth, 497 S.E.2d 474,
holding that arrest in backyard violated fourth amendment holding that arrest immediately out side of defendants house violated fourth amendment recognizing that the fourth amendment protects against the use of excessive force by police officers in carrying out an arrest holding a fourth amendment terry detention is not a custodial arrest and the use of handcuffs does not automatically convert a temporary detention into a fourth amendment arrest holding that arrest by the back door of defendants house was unlawful