## Facts

- Law enforcement received information that Charles R. Carney used a motor home to exchange marijuana for sexual favors.
- Agents observed Carney approach a youth who entered the motor home with him while it was parked in a downtown San Diego lot.
- After the youth exited, agents stopped him; he stated he had received marijuana in exchange for sexual contact with Carney.
- At agents’ direction, the youth returned and knocked; when Carney stepped out, an agent entered the motor home without a warrant or consent and saw marijuana.
- Officers took the motor home to a police facility and conducted a further search, finding additional marijuana.
- Carney was charged under state law with possession of marijuana for sale.
- The trial court denied Carney’s suppression motion; he entered a nolo contendere plea and was convicted.
- The state intermediate appellate court affirmed under the automobile exception; the state supreme court reversed, treating the motor home more like a dwelling; the U.S. Supreme Court reviewed and reversed.

## Issues

1. Whether a warrantless search of a motor home supported by probable cause violates the Fourth Amendment when the motor home is readily mobile and parked in a public, nonresidential setting.
2. Whether application of the automobile exception requires a separate showing of exigent circumstances beyond ready mobility and probable cause.

## Decision

- The Court reversed the state supreme court and held the warrantless search did not violate the Fourth Amendment.
- The motor home fell within the automobile exception because it was readily mobile, licensed for roadway use, and parked in a downtown lot rather than a residential location.
- The Court declined to require an additional exigency showing; probable cause plus the vehicle’s ready mobility and vehicle-like use sufficed.
- The Court found probable cause based on the information received, surveillance, and the youth’s statement describing a recent marijuana exchange.

## Legal Principles

- The automobile exception permits warrantless searches of vehicles when officers have probable cause, based principally on (1) ready mobility and (2) reduced expectations of privacy stemming from pervasive vehicle regulation.
- A motor home may be treated as a vehicle for Fourth Amendment purposes when it is capable of highway use and situated in circumstances indicating vehicle use rather than a fixed residence.
- Fourth Amendment analysis does not turn on a vehicle’s interior amenities; context and mobility are central.
- No independent exigency requirement applies beyond probable cause and the conditions that justify treating the object searched as a vehicle under the automobile exception.

## Conclusion

The Court held that a readily mobile motor home parked in a public, nonresidential location is subject to the automobile exception, making a warrantless search reasonable when supported by probable cause, even absent a separate showing of exigent circumstances.


California v. Carney, 471 U.S. 386 (1985)