## Facts

- State law enforcement officers arrested Kenneth and Judith Adams on outstanding warrants while they were outside their motor home, which was parked off-road in a secluded, wooded rural area of Suwannee County, Florida.
- After the arrests, officers secured the scene and then conducted a warrantless “investigative inspection and inventory search” of the motor home’s entire contents.
- The motor home was fully equipped and being used as the defendants’ residence; it contained personal effects and was connected to a generator.
- Information learned during the motor home search indicated the defendants rented multiple storage units.
- An officer used that information in affidavits to obtain warrants to search the storage facilities; officers then searched the units and seized additional evidence.
- The defendants moved to suppress evidence from the motor home as the product of an unlawful warrantless search and to suppress the storage-unit evidence as derivative of the initial illegality.

## Issues

1. Whether the warrantless search of the defendants’ motor home was valid under a Fourth Amendment exception, including the automobile exception, search incident to arrest, or a lawful inventory/evidence-seizure rationale.
2. If the motor home search was unlawful, whether evidence seized from the storage units pursuant to warrants based on information from that search must be suppressed as fruit of the poisonous tree, notwithstanding a claim of good-faith reliance on the warrants.

## Decision

- The court granted the motion to suppress.
- The warrantless search of the motor home violated the Fourth Amendment and was not justified by the automobile exception, search incident to arrest, or an inventory/evidence-seizure theory.
- The storage-unit warrants were supported by information obtained from the unlawful motor home search, making the storage-unit evidence suppressible as fruit of the poisonous tree.
- The good-faith exception did not save the storage-unit searches because the warrants’ probable cause was derived from the illegal search and the executing officers were aware of the taint.

## Legal Principles

- Warrantless searches are presumptively unreasonable unless the government proves a specifically recognized exception to the Fourth Amendment warrant requirement.
- A motor home used as a residence and situated in a settled, residential manner may be treated as a home for Fourth Amendment purposes rather than as a readily mobile automobile subject to reduced privacy expectations.
- Search incident to arrest is limited to the arrestee’s person and the area within the arrestee’s immediate control at the time of arrest; it does not justify a full search of a dwelling or dwelling-like space after occupants are removed and secured.
- A valid inventory search requires a non-investigatory purpose and compliance with standardized procedures; an evidence-gathering “inventory” label does not justify a warrantless search.
- Evidence derived from an unconstitutional search is generally suppressed unless the government shows attenuation, independent source, or inevitable discovery.
- The good-faith exception to the exclusionary rule does not apply where a warrant’s probable cause is founded on information obtained through an unlawful search known to the officers.

## Conclusion

The court held that the defendants’ motor home functioned as a protected dwelling in the circumstances presented, making the warrantless post-arrest search unconstitutional; because the storage-unit warrants were based on information from that search and no exception applied, all resulting evidence was suppressed.


United States v. Adams, 845 F. Supp. 1531 (M.D. Fla. 1994)