Lexis Nexis - Case Brief

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Law School Case Brief

New York v. Class - 475 U.S. 106, 106 S. Ct. 960 (1986)

Rule:

Because of the important role played by the Vehicle Identification Number (VIN) in the pervasive governmental regulation of the automobile and the efforts by the Federal Government to ensure that the VIN is placed in plain view, there is no reasonable expectation of privacy in the VIN.

Facts:

After observing a speeding car that had a cracked windshield, both of which were traffic violations, police officers directed the driver to stop the car. While the driver left the car and provided one officer with a registration certificate and proof of insurance (but admitted that he had no driver's license0, the other officer opened the left door of the car and checked the door jamb for the vehicle identification number (VIN). When the officer did not find the VIN on the door jamb, he reached into the car to move some papers, obscuring the area of the dashboard where the VIN was located, and in doing so, he saw the handle of a gun protruding from underneath the driver's seat. The officer seized the gun, and the driver was promptly arrested. After a motion to suppress the gun as evidence was denied, the driver was convicted, in the Supreme Court of Bronx County, New York, for illegal possession of a weapon. The Appellate Division of the Supreme Court, First Department, affirmed the conviction without opinion, but the New York Court of Appeals reversed, holding that a police officer's nonconsensual entry into an individual's car to determine the VIN  violated the Federal and New York Constitutions where it is based solely on a stop for a traffic infraction. The State of New York petitioned for a writ of certiorari.

Issue:

Did the police officer’s entry into the accused driver’s car to determine the VIN violate the Constitution, and thereby, any evidence obtained pursuant to such action should be held inadmissible against the accused?

Answer:

No.

Conclusion:

The United States Supreme Court held that the police officer's actions constituted a search and seizure for purposes of the Fourth Amendment, but that the search was constitutionally permissible. The Court held that the VIN, which was by law present in one of two locations, was ordinarily in plain view of someone outside of an automobile. Moreover, neither of the two locations was subject to a reasonable expectation of privacy. The Court held that the search was constitutionally permissible in light of the lack of a reasonable expectation of privacy in the VIN and in the fact that the officer observed respondent commit two traffic violations.

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