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Law School Case Brief

California v. Carney - 471 U.S. 386, 105 S. Ct. 2066 (1985)

Rule:

When a vehicle is being used on the highways, or if it is readily capable of such use and is found stationary in a place not regularly used for residential purposes -- temporary or otherwise -- the two justifications for the vehicle exception come into play. First, the vehicle is obviously readily mobile by the turn of an ignition key, if not actually moving. Second, there is a reduced expectation of privacy stemming from its use as a licensed motor vehicle subject to a range of police regulation inapplicable to a fixed dwelling.

Facts:

After receiving information that the exchange of marijuana for sex was taking place at defendant's motor home, which was parked on a public lot, law enforcement officials observed defendant and a youth enter the mobile home. The youth later stated that he received marijuana in exchange for sexual contacts with defendant. Without a warrant or consent, one agent entered the motor home and observed marijuana. Defendant was convicted for possession of marijuana for sale. The State challenged a ruling of the Supreme Court of California that a warrantless search of defendant's motor home was unreasonable because the vehicle exception to the warrant requirement did not apply as expectations of privacy in a motor home were more like those for a home than an automobile.

Issue:

Was the search of a motor home an exception to the warrant requirement?

Answer:

Yes

Conclusion:

The state supreme court reversed, holding that the warrantless search of the motor home was unreasonable as the vehicle exception to the warrant requirement did not apply. On certiorari, the United States Supreme Court reversed, holding that defendant's motor home clearly fell within the vehicle exception to the warrant requirement because it was readily mobile and was situated in a way or place that objectively indicated that it was being used as a vehicle. The Court reversed the judgment and remanded for further proceedings, holding that while defendant's motor home possessed some attributes of a home, it clearly fell within the vehicle exception to the warrant requirement because it was readily mobile and was situated in a way or place that objectively indicated that it was being used as a vehicle.

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