The U.S. Supreme Court on Tuesday ruled police must obtain a warrant to search a vehicle parked near a home on private property, setting new limits on law enforcement’s ability to conduct searches.
The justices ruled 8-1 in the case, which was one of several the Supreme Court heard this term that tested the boundaries of the Fourth Amendment. Justice Samuel Alito dissented.
The Supreme Court reversed the ruling from the Virginia Supreme Court and remanded the case for further proceedings.
The case before the justices saw a collision of two Fourth Amendment principles. Under one, police are required to obtain a warrant before searching the area around a house, called the curtilage. But the other permits a warrantless search of a vehicle as long as there is probable cause.
“In physically intruding on the curtilage of Collins’ home to search the motorcycle, Office Rhodes not only invaded Collins’ Fourth Amendment interest in the item searched, i.e. the motorcycle, but also invaded Collins’ Fourth Amendment interest in the curtilage of his home,” Justice Sonia Sotomayor wrote in the opinion for the majority. “The question before the court is whether the automobile exception justifies the invasion of the curtilage. The answer is no.”
The man at the center of the case is Ryan Collins, who twice eluded police while riding a motorcycle in Albemarle County, Va., in 2013. Officers eventually found the motorcycle covered with a tarp and parked on a parking patio outside a house belonging to Collins’ girlfriend.
Police lifted the tarp and ran the motorcycle’s vehicle identification number. Upon running the VIN, officers discovered the motorcycle had been stolen in New York several years earlier, and Collins was arrested.
Collins argued the police violated the Fourth Amendment with its warrantless search because the motorcycle was located within the curtilage of the home.
But a trial court, state appeals court, and the Virginia Supreme Court disagreed, and said the search was constitutional.
In its decision, the Virginia Supreme Court cited the Fourth Amendment’s automobile exception, under which an officer can search a vehicle without a warrant if he or she has probable cause to believe the vehicle was involved in a crime.
But the U.S. Supreme Court disagreed, saying nothing in its case law indicates that the automobile exception gave law enforcement the right to enter a home or its curtilage to access a vehicle without a warrant.
“Applying the relevant legal principles to a slightly different factual scenario confirms that this is an easy case,” Sotomayor wrote. “Imagine a motorcycle parked inside the living room of a house, visible through a window to a passerby on the street. Imagine further that an officer has probable cause to believe that the motorcycle was involved in a traffic infraction. Can the officer, acting without a warrant, enter the house to search the motorcycle and confirm whether it is the right one? Surely not.”
Unlike his other fellow justices, Alito called the police’s actions were “entirely reasonable” and said the officer involved had probable cause.
“An ordinary person of common sense would react to the court’s decision that way Mr. Bumble famously responded when told about a legal rule that did not comport with the reality of everyday life. If that is the law, he exclaimed, ‘the law is a ass—a idiot,” Alito wrote in his dissent, quoting Charles Dickens. “The Fourth Amendment is neither an ‘ass’ nor an ‘idiot.’ Its hallmark is reasonableness, and the court’s strikingly unreasonable decision is based on a misunderstanding of Fourth Amendment basics.”
The justices heard oral arguments in the case in January.
