## Facts

- Albemarle County, Virginia police investigated an “orange and black motorcycle with an extended frame” that twice fled officers at high speeds.
- Dashcam photos led police to a license plate previously registered to Eric Jones; Jones said he sold the motorcycle to Ryan Collins and warned him it was stolen.
- Officer David Rhodes found photos on Collins’ Facebook page showing a similar motorcycle parked in a driveway at a particular house.
- Rhodes went to the house and, from the street, saw what appeared to be the motorcycle under a tarp in a partially enclosed area at the top of the driveway next to the house.
- Without a warrant, Rhodes walked up the driveway into that area, lifted the tarp, checked the license plate and VIN, confirmed the motorcycle was stolen, photographed it, replaced the tarp, and waited.
- When Collins arrived, Rhodes arrested him and found a motorcycle key in his pocket.
- Collins moved to suppress evidence from the warrantless search, arguing the officer trespassed on the home’s curtilage protected by the Fourth Amendment.
- The trial court denied suppression and convicted Collins of receiving stolen property; Virginia appellate courts affirmed, with the Supreme Court of Virginia relying on the automobile exception.

## Issues

1. Whether the Fourth Amendment’s automobile exception permits a warrantless physical entry onto the curtilage of a home to search a vehicle parked there.
2. Whether lifting a tarp and inspecting identifying information on a vehicle within the curtilage constitutes a presumptively unreasonable search absent a warrant.

## Decision

- The Supreme Court reversed and remanded in an 8–1 decision.
- The Court held the automobile exception does not permit warrantless entry into a home or its curtilage to search a vehicle located there.
- The area where the motorcycle was parked—adjacent to the house in a partially enclosed portion of the driveway—qualified as curtilage.
- Officer Rhodes conducted a Fourth Amendment search by physically intruding on the curtilage to gather evidence when he entered the area and lifted the tarp.
- Because the search required crossing into a constitutionally protected area, probable cause to search the vehicle did not, by itself, justify the warrantless intrusion.

## Legal Principles

- Curtilage is treated as part of the home for Fourth Amendment purposes; a physical intrusion into curtilage to obtain evidence is a search presumptively unreasonable without a warrant.
- The automobile exception allows warrantless searches of vehicles based on probable cause, but it does not authorize warrantless entry into the home or its curtilage to reach a vehicle.
- Visibility of an object from a lawful public vantage point does not permit officers to enter protected property to conduct a search or manipulate coverings.
- The relevant constitutional question is whether police may lawfully enter the protected area to conduct the search, not merely whether probable cause exists to search the vehicle.

## Conclusion

The Court held that police may not rely on the automobile exception to enter a home’s curtilage without a warrant to search a vehicle parked there; the officer’s entry onto curtilage and lifting of the tarp was a presumptively unreasonable Fourth Amendment search.


Collins v. Virginia, 584 U.S. 586 (2018)