Facts
- Laguna Beach police received information that Billy Greenwood was dealing narcotics from his single-family residence.
- An investigator arranged with the neighborhood trash collector to retrieve Greenwood’s garbage bags left at the curb and provide them to police.
- Police searched the garbage bags without a warrant and found evidence suggestive of drug activity.
- Using the trash evidence, officers obtained a warrant to search Greenwood’s home and found cocaine and marijuana.
- Greenwood and Dyanne Van Houten were arrested on felony narcotics charges.
- A later, similar warrantless trash search generated additional evidence that supported a second search warrant.
Issues
- Whether the warrantless search and seizure of garbage left at the curb for collection outside the curtilage of a home violates the Fourth Amendment.
Decision
- The Supreme Court reversed the state appellate court.
- The Court held that the Fourth Amendment does not prohibit warrantless search and seizure of garbage left for collection outside the home’s curtilage.
- The Court concluded the respondents lacked an objectively reasonable expectation of privacy in curbside trash.
- The trash evidence could be used to support probable cause for the search warrants.
Legal Principles
- Fourth Amendment protection depends on whether a person has a reasonable expectation of privacy that society recognizes as reasonable.
- Garbage left at the curb for collection is exposed to the public and is accessible to others; an expectation of privacy in its contents is not objectively reasonable.
- When refuse is placed out for collection, it is conveyed to a third party; the person assumes the risk that the third party (or others) may examine or disclose its contents.
- Federal Fourth Amendment reasonableness is not defined by state-law privacy rules; a state’s more protective approach does not expand federal constitutional protection.
Conclusion
The Court held that police may, without a warrant, seize and search garbage left at the curb outside a home’s curtilage because individuals have no objectively reasonable expectation of privacy in refuse exposed to the public and placed for collection by a third party.