Collins v. Virginia

Facts of the Case

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 thewhen 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.

Question

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CONCLUSION

“The Fourth Amendment’s automobile exception does not permit a police officer without a warrant to enter private property to search a vehicle parked a few feet from the house. In an 8–1 opinion authored by Justice Sonia Sotomayor, the Court held that its own Fourth Amendment jurisprudence regarding the home and the “curtilage” of one’s home (the area immediately surrounding it) clearly prevents officers from entering and searching without a warrant, even if the object searched is an automobile. The Court found that the area searched (the back of the driveway) was indeed the curtilage of the defendant’s home, and thus the Fourth Amendment’s highest degree of protection applies there. Although warrantless searches of automobiles are permissible in limited circumstances, the warrantless search of an automobile parked within the curtilage of one’s home is not permissible.Justice Clarence Thomas wrote a concurring opinion to express doubt about the Court’s authority to impose the exclusionary rule on the states.Justice Samuel Alito wrote a dissenting opinion in which he opined that the automobile exception should apply in this case and that the search was in no way “unreasonable.””

Case Information

Citation: 584 US (2018)
Granted: Sep 28, 2017
Argued: Jan 9, 2018
Decided: May 29, 2018
Case Brief: 2018