Law School Case Brief
United States v. Knotts - 460 U.S. 276, 103 S. Ct. 1081 (1983)
One has a lesser expectation of privacy in a motor vehicle because its function is transportation and it seldom serves as one's residence or as the repository of personal effects. A car has little capacity for escaping public scrutiny. It travels public thoroughfares where both its occupants and its contents are in plain view. A person traveling in an automobile on public thoroughfares has no reasonable expectation of privacy in his movements from one place to another.
Government officers installed a beeper device, which emitted periodic signals that could be picked up by a radio receiver, inside a container of chloroform. A codefendant purchased the chloroform and then delivered it to defendant Darryl Petschen. Petschen placed the container in his car; the officers followed Petschen by maintaining contact by using both visual surveillance and the monitor that received the signals sent from the beeper. Through the use of the beeper the officers ultimately traced the chloroform to a secluded cabin owned by defendant Leroy Carlton Knotts. The officers secured a search warrant after three days of intermittent visual surveillance of the cabin. In the subsequent search, officers discovered a clandestine drug laboratory in the cabin and the container of chloroform under a barrel outside the cabin. At trial in federal district court, the district court denied defendants' motion to suppress evidence based on the warrantless monitoring of the beeper. Defendants were convicted for conspiring to manufacture controlled substances in violation of 21 U.S.C.S. § 846. On appeal, the court of appeals reversed Knotts' conviction on the ground that the beeper had been placed on his residential property where he was entitled to exercise a reasonable, legitimate Fourth Amendment expectation of privacy. The court of appeals affirmed Petschen's conviction because he did not have a reasonable expectation of privacy while in the car or on Knotts' land. The Government was granted a writ of certiorari.
Was Knotts' right secured by the Fourth Amendment of the U.S. Constitution violated by the governmental surveillance conducted by means of the beeper?
The Supreme Court of the United States reversed the appellate court's judgment. The Court observed that while Knotts had the traditional expectation of privacy within a dwelling place insofar as his cabin was concerned, such expectation of privacy did not extend to the visual observation from public places of the automobile arriving on his premises after leaving a public highway, or to movements of objects such as the chloroform container outside the cabin. The fact that the officers relied not only on visual surveillance, but also on the use of the beeper, did not alter the situation. Nothing in the Fourth Amendment prohibited the police from augmenting their sensory faculties with such enhancement as science and technology afforded them in the instant case.
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