of privacy." Litchfield, 824 N.E.2d at 359. This particular rationale is premised on the notion that by depositing the trash in a place accessible to the public for collection, "the depositor has relinquished any reasonable expectation of privacy." Id. (quoting State v. Sampson, 362 Md. 438, 765 A.2d 629, 634 (2001)). When considering the cireumstances here, I note that the purpose of the exclusionary rule is to deter police misconduct. See Osborne v. State, 805 N.E.2d 435, 439 (Ind.Ct.App.2004), trans. denied. Prior to the rule announced in Litchfield, the conduct of the officers here was not unreasonable or improper, inasmuch as they were free to "grab" Turner's curbside trash without meeting any standard of individualized suspicion. See Moran v. State, 644 N.E.2d 536, 541 (Ind.1994) (<HOLDING>). That said, it follows that Turner's decision
holding that random searches of subway passengers carryon bags which include the visual inspection of the contents of such bags to be minimal holding tacit consent to search of person was insufficient to prove consent to search bags where bags were not in defendants actual possession defendant merely pointed out bags at officers request and officer never specifically asked for consent to search bags holding that one who places trash bags for collection intends for them to be taken up holding that the expenses of depositions taken merely for discovery purposes should be borne by the party taking them holding warrantless searches of garbage bags left on curb for collection invalid under state constitution