584 U.S. 120, 138 S. Ct. 1663, 201 L. Ed. 2d 9 (2018)
Ryan Austin Collins was indicted in Virginia state court for receiving stolen property after police discovered a stolen motorcycle in the driveway of a house where he stayed several nights a week.1 In the summer of 2013, Officer Matthew McCall observed an orange and black motorcycle with an extended frame commit a traffic infraction, but the driver eluded him.2 Weeks later, Officer David Rhodes observed the same motorcycle exceeding the speed limit, but the driver again escaped apprehension.3
The officers compared notes and concluded that the two incidents involved the same motorcyclist.4 Upon further investigation, the officers learned that the motorcycle likely was stolen and in the possession of petitioner Ryan Collins.5 Officer Rhodes located photographs on Collins’ Facebook profile depicting the motorcycle parked in the driveway of a house.6 Rhodes drove to the address, parked on the street, and observed a motorcycle covered by a white tarp in the driveway matching the photographs.7
Without obtaining a warrant, Rhodes walked onto the property, up the driveway, removed the tarp, confirmed the motorcycle was stolen by checking its license plate and vehicle identification numbers, photographed it, replaced the tarp, and waited for Collins to return.8 Upon Collins’ arrival, Rhodes arrested him after Collins admitted purchasing the motorcycle without title.9 Collins filed a pretrial motion to suppress the evidence obtained from the search of the motorcycle.10 The trial court denied the motion, and Collins was convicted following trial.11
The Court of Appeals of Virginia affirmed the conviction.12 The Supreme Court of Virginia affirmed on the ground that the warrantless search was justified by the automobile exception to the Fourth Amendment warrant requirement.13 The United States Supreme Court granted certiorari to review the case.14
Whether the automobile exception to the Fourth Amendment permits a police officer, uninvited and without a warrant, to enter the curtilage of a home to search a vehicle parked therein?15
The automobile exception permits warrantless searches of vehicles when officers have probable cause.16 The exception rests on the ready mobility of the vehicle and the reduced expectation of privacy in vehicles.17 The exception does not extend to vehicles parked within the curtilage of a home because the curtilage receives the same Fourth Amendment protection as the home itself.18
No. Officer Rhodes walked onto the residential property and up the driveway to remove the tarp from the motorcycle without a warrant.19 The motorcycle was parked in the driveway of the house where Collins stayed several nights per week.20 The rationales for the automobile exception account only for the balance between the intrusion on the vehicle interest and governmental interests in an expedient search.21 They do not account for the distinct privacy interest in the curtilage.
The automobile exception does not permit the warrantless search of the motorcycle parked in the curtilage.22
Related opinions on this issue
Justice Thomas joined the opinion of the Court.23 He wrote separately to express serious doubts about this Court’s authority to impose the exclusionary rule on the States.24 The exclusionary rule is not rooted in the Constitution or a federal statute, as it postdates the founding by more than a century and contradicts longstanding common-law principles.25
At the founding, curtilage was considered part of the house itself, and house searches required a specific warrant even for stolen goods.26 Historical remedies for unconstitutional searches were tort suits and self-help rather than suppression of evidence.27 The Founders would not have understood the logic of the exclusionary rule.28 The rule is federal common law that cannot bind the States under the Supremacy Clause, which applies only to the Constitution, statutes, and treaties, not judge-made doctrines.29
Joined by Chief Justice Roberts (as To Part I)
Justice Alito dissented and argued that the search was reasonable under the Fourth Amendment.30 The motorcycle remained readily mobile even when parked in the driveway, as it could have been uncovered and ridden away in seconds.31 The brief walk up the driveway caused no harm to any privacy interest, and Officer Rhodes observed nothing he could not have seen from the street.32
The reasons for the automobile exception remain valid when the vehicle is parked in a driveway just a few feet from the street.33 Unlike other warrant exceptions, the automobile exception has no separate exigency requirement because mobility categorically obviates case-specific inquiry.34 Therefore the automobile exception should apply and the judgment below should be affirmed.35
Whether the portion of the driveway where the motorcycle was parked constitutes curtilage?36
Curtilage is the area immediately surrounding and associated with the home.37 It is considered part of the home itself for Fourth Amendment purposes. Courts determine curtilage by factors including proximity to the home, enclosure surrounding the home, nature of the uses, and steps taken to protect the area from observation.38
Yes. The motorcycle was parked inside the partially enclosed top portion of the driveway that abuts the house.39 The enclosure was formed by a brick wall on two sides and the house on the third side.40 A side door provides direct access between the enclosure and the house.41 This area is adjacent to the home and constitutes an area to which the activity of home life extends.42
The portion of the driveway where the motorcycle was parked constitutes curtilage.43