People v. Tobias Boyland
Issue before the Court: Whether, in executing a search warrant for a lower floor apartment, the police properly conducted a "protective sweep" on an upper floor.
Held: "Whether a protective sweep is justified under particular circumstances involves a mixed question of law and fact" beyond the Court's powers of review, which is limited to issues of law. The defendant's appeal is dismissed.
CAL observes: On SSM review, and without providing any reasoning or citing any case, the Court has now added one more category of issue that is immune from Court of Appeals review.