State v. Kolb, 2008 Ohio 3265 (Ohio Ct. App. 2008)

(arrest of defendant not within curtilage of home and, therefore, not within home’s umbrella of Fourth Amendment protection; while arrest occurred within close proximity of home, area not enclosed by fence or any form of enclosure and defendant did not engage in activities in front of home in which he engaged in private areas of home; area in which arrest occurred observable from highway).