SCOTUS ruling sets limits on Fourth Amendment’s ‘vehicle exception’

In a victory for Fourth Amendment activists on Tuesday, the U.S. Supreme Court determined a carport and a driveway fall under the definition of a home, thereby requiring law enforcement to obtain a warrant to search vehicles parked on one’s private residential property.

The case, Collins v. Virginia, revolved around an exception to the Fourth Amendment requirement for a warrant, known as the “automobile exception.”

The “vehicle exception” allows police to conduct a search of an automobile parked on the street or other public property.

An 8–1 decision, the High Court reversed and remanded a Virginia state court ruling in which two police officers pursued one Ryan Collins on what they believed was a stolen motorcycle in 2014.

After eluding police, authorities later located Collins and discovered the stolen motorcycle concealed under a tarp on property owned by Collins’ girlfriend.  Collins argued the warrantless search conducted violated his right against unreasonable search and seizure.

Writing for the majority, Associate Justice Sonia Sotomayor judged in curtilage, the land surrounding a home structure, requires a search warrant.

“In physically intruding on the curtilage of (Ryan Austin) Collins’ home to search the motorcycle (the officer) not only invaded Collins’ Fourth Amendment interest in the item searched, i.e., the motorcycle, but also invaded Collins’ Fourth Amendment interest in the curtilage of his home,” Sotomayor ruled.

Virginia had argued the search was legal on the grounds some curtilage, a driveway for example, should remain available for warrantless searches without infringing on a home or other structures on the property.

Countering the lower court ruling, Sotomayor argued the earlier decision by the Supreme Court of Virginia deprived persons without financial means consideration over areas determined by the owner as curtilage.

Describing the police officer’s actions during the search as “not impairing privacy interests,” in his dissenting opinion filing, Associate Justice Samuel Alito invoked “Oliver Twist”and wrote: “An ordinary person of common sense would react to the Court’s decision the way Mr. Bumble famously responded when told about a legal rule that did not comport with the reality of everyday life. ‘If that is the law, the law is a ass — a idiot.'”

 

[Jurist] [SCOTUSblog] [The Hill] [Photo courtesy Shutterstock via Shawn Curry Law]