Law School Case Brief
Collins v. Virginia - 138 S. Ct. 1663 (2018)
The scope of the automobile exception to the Fourth Amendment extends no further than the automobile itself. The automobile exception permits police to search the vehicle. The Framers would have regarded as reasonable (if there was probable cause) the warrantless search of containers within an automobile. Nothing in the case law from the Supreme Court of the United States suggests that the automobile exception gives an officer the right to enter a home or its curtilage to access a vehicle without a warrant. Expanding the scope of the automobile exception in this way would both undervalue the core Fourth Amendment protection afforded to the home and its curtilage and untether the automobile exception from the justifications underlying it.
During the investigation of two traffic incidents involving an orange and black motorcycle with an extended frame, Officer David Rhodes learned that the motorcycle likely was stolen and in the possession of petitioner Ryan Collins. Officer Rhodes discovered photographs on Collins' Facebook profile of an orange and black motorcycle parked in the driveway of a house, drove to the house, and parked on the street. From there, he could see what appeared to be the motorcycle under a white tarp parked in the same location as the motorcycle in the photograph. Without a search warrant, Office Rhodes walked to the top of the driveway, removed the tarp, confirmed that the motorcycle was stolen by running the license plate and vehicle identification numbers, took a photograph of the uncovered motorcycle, replaced the tarp, and returned to his car to wait for Collins. When Collins returned, Officer Rhodes arrested him. At trial in Virginia commonwealth court, the trial court denied Collins' motion to suppress the evidence on the ground that Officer Rhodes violated the Fourth Amendment when he trespassed on the house's curtilage to conduct a search. Collins was convicted of receiving stolen property. The Court of Appeals Virginia affirmed. The Supreme Court of Virginia also affirmed, holding that the warrantless search was justified under the Fourth Amendments automobile exception. Collins was granted a writ of certiorari.
Did the automobile exception permit the officer's warrantless entry of a home or its curtilage in order to search a vehicle therein?
The Supreme Court of the United States reversed the judgment from the Supreme Court of Virginia and remanded the matter for further proceedings. The Court ruled that the partially enclosed section of the driveway where the motorcycle was parked constituted curtilage protected by the Fourth Amendment. The automobile exception did not afford the necessary lawful right of access to search the motorcycle parked within a home or its curtilage because it did not justify an intrusion on Collins' separate and substantial Fourth Amendment interest in his home and curtilage. The Court left for resolution on remand whether Officer Rhodes' warrantless intrusion on the curtilage of Collins' house may have been reasonable on a different basis, such as the exigent circumstances exception to the warrant requirement.
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