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Try CasePortal for FreeJ. Gill finds the circuit court improperly denied defendant's motion to suppress evidence of marijuana discovered from searches police conducted of her car with a canine during a traffic stop for not having a front license plate and a passenger not wearing a seat belt. The searches of defendant's car, which occurred when a canine being led around the outside of the car was allowed to twice enter defendant's open driver's side door, both count as "searches" under the Fourth Amendment, and they constitute unlawful searches because the officers did not get a warrant and no exception to the warrant requirement was at play. Whether or not the standard adopted by some jurisdictions creating an exception to the warrant requirement if a canine instinctively extends a search into someone's car exists and is recognized in Wisconsin, such an "instinct exception" will not be adopted in this case because the officer handling the canine "implicitly encouraged" it to enter defendant's car. The circuit court's judgment of conviction is reversed and the case is remanded for the circuit court to grant defendant's motion to suppress. Reversed.