was arrested just outside the door of the residence). The location of the arrest outside the home is relevant in determining whether officers had the requisite “reasonable articulable suspicion” of a threat to their safety. Colbert, 76 F.3d at 776-77; see Henry, 48 F.3d at 1284 (recognizing that the location of the arrest outside the dwelling is relevant to the issue of whether the officers could reasonably fear an attack by someone inside). We are not persuaded that the protective sweep in this case was reasonable because the State failed to show that the agents had sufficient articulable facts to reasonably conclude that other people might be hiding who posed a threat to the agents or others at the arrest scene. See United States v. Carter, 360 F.3d 1235, 1242 (10th Cir. 2004) (<HOLDING>); Colbert, 16 F.3d at 778 (holding that an
holding that the protective sweep incident to the defendants arrest in front of his house on suspicion of murder was not justified because the evidence that an accomplice was involved in the murder did not equate to evidence that someone would be hiding out in the defendants house a month after the crime occurred and at the time of the arrest the officers were not chasing the defendant from a crime scene holding that protective sweep was justified incident to arrest outside residence where officers had reasonable suspicion that dangerous individuals were in apartment holding that officers were not justified in conducting a protective sweep of the suspects garage and backyard incident to his arrest for possession of marijuana in the back yard because the government pointed to no specific articulable facts suggesting that someone else was on the premises who posed a danger to the officers holding that officers were not justified in conducting a protective sweep incident to the defendants arrest despite the defendants alleged involvement with narcotics and possession of weapons because the defendant did not resist and there was no noise or other evidence suggesting anyone else was present in the house holding that the officers were justified in conducting a protective sweep incident to the defendants arrest on outstanding warrants because the officers had information that the defendant was suspected of running a methamphetamine operation on the premises other people were living there and assisting the defendant and at the time the sweep began the defendant had not yet been located