Open fields. Courts ruled that an 'open field' includes structures in a fenced field that are not part of the curtilage of a residence.
Terry v Ohio (1968)
1. LEO 'seizes' a person by keeping them from leaving. 2. LEO 'searches' even with patting of exterior clothing. 3. Must be reasonable to be justified under 4th Amendment. 4. Reasonableness based on articulable facts of criminal activity or armed subject. 5. mere 'hunch' insufficient, must have reasonable suspicion.