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
- Whether the Fourth Amendment’s automobile exception permits a warrantless physical entry onto the curtilage of a home to search a vehicle parked there.
- 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.