California v. Carney Case Brief

Why is the case important?

The defendant, Charles Carney (the “defendant”), was arrested for possession of marijuana for sale, after police surveyed the defendant’s parked motor home. The police did not obtain a warrant for the arrest and subsequent search.

Facts of the case

“On May 31, 1979, Drug Enforcement Agency officers observed Charles Carney approach a youth who followed him into a motor home parked in a lot in downtown San Diego. Having previously received a tip that Carney was using the motor home to sell marijuana in exchange for sexual favors, the officers kept the motor home under surveillance while the two were inside. When the youth exited, the officers contacted him, and he confirmed that Carney gave him marijuana in exchange for receiving Carney’s sexual advances. The officers knocked on the door of the mobile home, identified themselves, and entered without a warrant or consent. They found marijuana, plastic bags, and a scale on the table. The officers arrested Carney for possession of marijuana with intent to sell.Carney moved to suppress the evidence discovered in the warrantless search of the motor home, and the trial court denied the motion. Carney pleaded no contest, was convicted, and placed on probation. He appealed, and the California Court of Appeals upheld the conviction on the grounds that the motor home fell under the vehicle exception to the Fourth Amendment. The Supreme Court of California reversed.”

Question

Whether the police needed a search warrant to search the parked mobile home?

Answer

The Supreme Court of the United States (Supreme Court) held that the police did not need a search warrant before searching the motor home. The Supreme Court referred to their ruling as the automobile exception, which states that there is a lesser degree of protection for motor vehicles because they can be quickly moved out of the area. The Supreme Court added that the open nature of vehicles as compared with a permanent structure would warrant a lesser expectation of privacy. Government regulation of vehicles would also suggest that there is a lower expectation of privacy for a vehicle as compared to a fixed structure.

Conclusion

T he 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.

  • Case Brief: 1985
  • Petitioner: California
  • Respondent: Charles R. Carney
  • Decided by: Burger Court

Citation: 471 US 386 (1985)
Argued: Oct 30, 1984
Decided: May 13, 1985
Granted Mar 19, 1984