Collins v. Virginia

Last updated
Collins v. Virginia
Seal of the United States Supreme Court.svg
Supreme Court of the United States
Argued January 9, 2018
Decided May 29, 2018
Full case nameRay Austin Collins v. Virginia
Docket no. 16-1027
Citations584 U.S. ( more )
138 S. Ct. 1663; 201 L. Ed. 2d 9
Argument Oral argument
Case history
PriorCollins v. Commonwealth, 292 Va. 486, 790 S.E.2d 611 (2016); cert. granted, 138 S. Ct. 53 (2017).
Holding
The Fourth Amendment's motor vehicle exception for a warrantless search based on reasonable cause does not apply to vehicles stored within a person's home or its curtilage.
Court membership
Chief Justice
John Roberts
Associate Justices
Anthony Kennedy  · Clarence Thomas
Ruth Bader Ginsburg  · Stephen Breyer
Samuel Alito  · Sonia Sotomayor
Elena Kagan  · Neil Gorsuch
Case opinions
MajoritySotomayor, joined by Roberts, Kennedy, Thomas, Ginsburg, Breyer, Kagan, Gorsuch
ConcurrenceThomas
DissentAlito

Collins v. Virginia, No. 16-1027, 584 U.S. ___ (2018), was a case before the US Supreme Court involving search and seizure. At issue was whether the Fourth Amendment's motor vehicle exception permits a police officer uninvited and without a warrant to enter private property, approach a house, and search a vehicle parked a few feet from the house that is otherwise visible from off the property. [1] In an 8–1 judgement, the Supreme Court ruled that the automobile exception does not apply to vehicles parked within the home or the curtilage of a private homeowner. [2]

Contents

Background

In Albemarle County, Virginia, Officer David Rhodes observed from the street what appeared to be a motorcycle with a distinctive appearance under a tarp parked on the property of a home in which the Charlottesville resident Ryan Austin Collins was staying. Rhodes had recognized the colors from a previous high-speed chase two months earlier in which the rider of the motorcycle had eluded him. Officer Rhodes obtained the vehicle's license plate number using footage from his dashcam video. [3] Rhodes then found photographs of the motorcycle on Collins's Facebook pages that appeared to be taken from where he had seen it parked, which was near the home in an area that was walled on one side by the home and on two sides by a short brick wall. With that as probable cause, Rhodes entered the property in the absence of Collins and, without a warrant, lifted the tarp, took additional photographs, and determined that the bike had been stolen. When Collins returned to the home, Rhodes arrested him on charges of stealing the bike, and the key to the motorcycle was discovered in Collins's possession on arrest. Collins denied owning or having ridden the bike for months. [4] [5]

At trial court, Collins argued that the police had illegally entered the property to search it, as the vehicle was parked with the walled area that he considered the curtilage of the home, a violation under the Fourth Amendment, and sought to void the evidence taken by Rhodes's search.

The state argued that the previous chase and both photographs Collins had posted on Facebook of himself and the motorcycle were sufficient probable cause. [6] [ original research? ] The trial court agreed with the state that Rhodes has probable cause to search under the tarp. The ruling was upheld both in the state's appeal courts and in the Virginia Supreme Court, with the latter affirming that Rhodes's search was proper under the motor vehicle exception to the Fourth Amendment defined by past Supreme Court cases, which allowed for warrantless searches for automobiles with probable cause. [4]

Supreme Court

Collins petitioned the Supreme Court for writ of certiorari on whether the Fourth Amendment protected his rights of privacy for the area a few feet from the boundaries of his home. The Supreme Court agreed in September 2017 to hear the case. The Court heard oral arguments on January 9, 2018. [7]

In oral arguments, the Justices discussed the curtilage, the homeowner's expectation of privacy there, and the officer's right to enter on the property. They discussed the officer's right to lift the tarp, which was potentially a search. Also, they discussed the difference between an automobile, which is potentially mobile and creates an exigent circumstance for search, with drugs or papers, which are immobile. The discussion devolved into a discussion of the differences between garage, carport, driveway, and street. Justice Ginsburg pointed out that protection of the garage but not a driveway burdens people who cannot afford a garage. [7] [ original research? ]

Decision

The Court announced judgment in favor of the accused on May 29, 2018, reversing and remanding the case back to lower courts. [8] The Court ruled 8–1 that the automobile exemption does not include the home or curtilage and that vehicles that are stored within the home's curtilage cannot be searched without a warrant. [9] Justice Sonia Sotomayor wrote the majority opinion, which was joined by all but Justice Samuel Alito.

Justice Clarence Thomas also wrote a concurring opinion agreeing with the decision but questioning if the Court had the right to force states to suppress incriminating evidence that was obtained unconstitutionally, as that would be akin to forcing states to follow the federal exclusionary rule. [4]

Alito wrote the sole dissenting opinion, arguing that whether the motorcycle was parked in the curtilage or not was unnecessary since the motorcycle was within plain view and so there was a reasonable cause for the officer to examine the vehicle. [4]

See also

Related Research Articles

<span class="mw-page-title-main">Fourth Amendment to the United States Constitution</span> 1791 amendment prohibiting unreasonable searches and seizures

The Fourth Amendment to the United States Constitution is part of the Bill of Rights. It prohibits unreasonable searches and seizures. In addition, it sets requirements for issuing warrants: warrants must be issued by a judge or magistrate, justified by probable cause, supported by oath or affirmation, and must particularly describe the place to be searched and the persons or things to be seized.

A search warrant is a court order that a magistrate or judge issues to authorize law enforcement officers to conduct a search of a person, location, or vehicle for evidence of a crime and to confiscate any evidence they find. In most countries, a search warrant cannot be issued in aid of civil process.

<span class="mw-page-title-main">Search and seizure</span> Police power to confiscate any relevant evidence found in connection to a crime

Search and seizure is a procedure used in many civil law and common law legal systems by which police or other authorities and their agents, who, suspecting that a crime has been committed, commence a search of a person's property and confiscate any relevant evidence found in connection to the crime.

United States v. Ross, 456 U.S. 798 (1982), was a search and seizure case argued before the Supreme Court of the United States. The high court was asked to decide if a legal warrantless search of an automobile allows closed containers found in the vehicle to be searched as well. The appeals court had previously ruled that opening and searching the closed portable containers without a warrant was a violation of the Fourth Amendment, even though the warrantless vehicle search was permissible due to existing precedent.

<span class="mw-page-title-main">Open-fields doctrine</span> N.Z. legal rule allowing warrantless searches of private property not near houses

The open-fields doctrine, in the U.S. law of criminal procedure, is the legal doctrine that a "warrantless search of the area outside a property owner's curtilage" does not violate the Fourth Amendment to the United States Constitution. However, "unless there is some other legal basis for the search," such a search "must exclude the home and any adjoining land that is within an enclosure or otherwise protected from public scrutiny."

California v. Greenwood, 486 U.S. 35 (1988), was a case in which the Supreme Court of the United States held that the Fourth Amendment does not prohibit the warrantless search and seizure of garbage left for collection outside the curtilage of a home.

<span class="mw-page-title-main">Motor vehicle exception</span> United States legal rule allowing a police officer to search a motor vehicle without a warrant

The motor vehicle exception is a legal rule in the United States that modifies the normal probable cause requirement of the Fourth Amendment to the United States Constitution and, when applicable, allows a police officer to search a motor vehicle without a search warrant.

In United States criminal law, the border search exception is a doctrine that allows searches and seizures at international borders and their functional equivalent without a warrant or probable cause. Generally speaking, searches within 100 miles of the border are more permissible without a warrant than those conducted elsewhere in the U.S. The doctrine also allows federal agents to search people at border crossings without a warrant or probable cause. The government is allowed to use scanning devices and to search personal electronics. Invasive bodily searches, however, require reasonable suspicion.

Welsh v. Wisconsin, 466 U.S. 740 (1984), was a 1983 case before the US Supreme Court determining that a warrantless arrest violates the Fourth Amendment protection against unlawful search and seizure.

California v. Acevedo, 500 U.S. 565 (1991), was a decision of the United States Supreme Court, which interpreted the Carroll doctrine to provide one rule to govern all automobile searches. The Court stated, "The police may search an automobile and the containers within it where they have probable cause to believe contraband or evidence is contained." The decision also overruled the distinctions in United States v. Chadwick (1977) and Arkansas v. Sanders (1979) which had previously held that, if probable cause existed to search an automobile, the police may perform a warrantless search of the automobile and the containers within it, but if the police only had probable cause to search a container in the automobile, the police first had to obtain a warrant before searching the container.

Carroll v. United States, 267 U.S. 132 (1925), was a decision by the United States Supreme Court that upheld the warrantless searches of an automobile, which is known as the automobile exception. The case has also been cited as widening the scope of search.

Arizona v. Gant, 556 U.S. 332 (2009), was a United States Supreme Court decision holding that the Fourth Amendment to the United States Constitution requires law enforcement officers to demonstrate an actual and continuing threat to their safety posed by an arrestee, or a need to preserve evidence related to the crime of arrest from tampering by the arrestee, in order to justify a warrantless vehicular search incident to arrest conducted after the vehicle's recent occupants have been arrested and secured.

Chambers v. Maroney, 399 U.S. 42 (1970), was a United States Supreme Court case in which the Court applied the Carroll doctrine in a case with a significant factual difference—the search took place after the vehicle was moved to the stationhouse. The search was thus delayed and did not take place on the highway as in Carroll. After a gas station robbery, a vehicle fitting the description of the robbers' car was stopped. Inside were people wearing clothing matching the description of that worn by the robbers. They were arrested, and the car was taken to the police station where it was later searched.

Almeida-Sanchez v. United States, 413 U.S. 266 (1973), was a United States Supreme Court case holding that the search of an automobile by the United States Border Patrol without a warrant or probable cause violates the Fourth Amendment. The vehicle was stopped and searched for illegal aliens twenty-five miles (40 km) from the Mexican border. The Court approached the search from four views: automobile search, administrative inspection, heavily regulated industry inspection, and border search. As to the validity of the search under the automobile exception, the Court found no justification for the search under the Carroll doctrine because there was no probable cause. As to the validity of the search under various administrative inspection doctrines, the Court found that the officers lacked an area warrant. As to the validity of the heavily regulated industry inspection, the Court found that the doctrine is not applicable to traveling on a state highway. As to the validity of a border search, the Court found that the site of the stop and the entirety of the road on which the stop occurred was too far from the border to be considered a border search.

Kentucky v. King, 563 U.S. 452 (2011), was a decision by the US Supreme Court, which held that warrantless searches conducted in police-created exigent circumstances do not violate the Fourth Amendment as long as the police did not create the exigency by violating or threatening to violate the Fourth Amendment.

In United States Constitutional Law, a minimally intrusive/invasive warrantless search is a type of search that does not breach the boundaries of the property and is performed without any prerequisite search warrant. These searches are contested regularly in courts, and have been ruled for and against under different circumstances. The primary debate concerns the method in which the search is conducted, and also the area being searched. Issues concerning warrantless search and subsequent seizure are always of local concern, because they are a community law enforcement issue as well as a national law issue.

<i>Florida v. Jardines</i> 2013 United States Supreme Court case

Florida v. Jardines, 569 U.S. 1 (2013), was a United States Supreme Court case which resulted in the decision that police use of a trained detection dog to sniff for narcotics on the front porch of a private home is a "search" within the meaning of the Fourth Amendment to the United States Constitution, and therefore, without consent, requires both probable cause and a search warrant.

United States v. Watson, 423 U.S. 411 (1976), was a case decided by the Supreme Court of the United States that decided that a warrantless arrest in public and consenting to a vehicle search did not violate the Fourth Amendment.

Johnson v. United States, 333 U.S. 10 (1948), was a significant United States Supreme Court decision addressing search warrants and the Fourth Amendment. In this case, where federal agents had probable cause to search a hotel room but did not obtain a warrant, the Court declared the search was "unreasonable."

Lange v. California, 594 U.S. ___ (2021), was a United States Supreme Court case involving the exigent circumstances requirement related to the Fourth Amendment to the United States Constitution. The Court ruled unanimously that the warrantless entry into a home by police in pursuit of a misdemeanant is not unequivocally justified.

References

  1. ↑ Chappell, Hugh (September 28, 2017). "Supreme Court Adds More Cases To 2017-2018 Term, Including Union Dispute". NPR. Retrieved 28 September 2017.
  2. ↑ Collins v. Virginia,No. 16-1027 , 584 U.S. ___(2018).
  3. ↑ "Collins v. Virginia". Harvard Law Review. 132: 357. Nov 9, 2018. Retrieved November 27, 2021.
  4. 1 2 3 4 Sherman, Mark (May 29, 2018). "Supreme Court limits warrantless vehicle searches near homes". Associated Press . Retrieved May 29, 2018.
  5. ↑ Barnes, Robert (May 29, 2018). "Supreme Court says warrants needed to search vehicles on private property". The Washington Post . Retrieved May 29, 2018.
  6. ↑ Collins v. Commonwealth, 292 Va. 486, 790 S.E.2d 611 (2016).
  7. 1 2 "Collins v. Virginia" (PDF). Supreme Court of the United States. January 9, 2018. Retrieved 13 January 2018.
  8. ↑ Liptak, Adam (29 May 2018). "Police Need Warrants for Driveway Searches, Supreme Court Rules". The New York Times . Retrieved 7 July 2019.
  9. ↑ Note, The Supreme Court, 2017 Term — Leading Cases , 132 Harv. L. Rev. 357 (2018).
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