These cases should have alerted any reasonable officer that the Fourth Amendment forbids the killing of a person's dog, or the destruction of a person's property, when that destruction is unnecessary — i.e., when less intrusive, or less destructive, alternatives exist. It is no doubt true, as the Third Circuit's Brown case hypothesized, that there are potential cases in which the state's interest may be sufficiently compelling to 'justify the extreme intrusion occasioned by the destruction of the pet.' Jeremy robinson hells angel. A reasonable officer should have known that to create a plan to enter the perimeter of a person's property, knowing all the while about the presence of dogs on the property, without considering a method for subduing the dogs besides killing them, would violate the Fourth Amendment. Brown, 269 F.3d at 210-11. City of San Antonio, 139 F.3d 441, 450 (5th Cir.
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