The Supreme Court curbed law enforcement’s power to search automobiles without a warrant on Tuesday, holding that if a vehicle is located on private property adjacent to a house police will generally need to meet a higher burden before searching it.
Justice Sonia Sotomayor wrote the 8-1 opinion, sending the case back down to a lower court to determine whether there may have been other justifications for the warrant-less search.
“This case presents the question whether the automobile exception to the Fourth Amendment permits a police officer, uninvited without a warrant, to enter the curtilage of a home in order to search a vehicle parked therein,” she wrote. “It does not,” she wrote.
The case began in 2013 when officers in Albemarle County in Virginia noted an orange and black motorcycle commit a traffic violation. The driver of the motorcycle managed to get away. A few weeks later one of the officers, David Rhodes, saw the motorcycle again traveling well over the speed limit. After further investigation they learned it was in the possession of Ryan Collins and parked in the driveway of his girlfriend.
Without a warrant, Rhodes walked up the driveway and took a picture of the motorcycle. He pulled off the tarp and ran a search of the license plate.
Once he confirmed that the motorcycle had been stolen he left the property and waited for Collins to arrive before arresting him.
Lawyers for Collins later argued to suppress the evidence.
Sotomayor noted that in the past the court has held that a search of an automobile can be conducted without a warrant under certain circumstances. But she said that the so called “automobile exception” does not apply when the vehicle is so near to a home.
She sent the case back to the lower court to determine whether 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.”
