506 U.S. 56 (1992)
Edward Soldal and his family resided in their trailer home on a rented lot in the Willoway Terrace mobile home park in Elk Grove, Illinois.1 In May 1987 Terrace Properties, the park owner, and its manager Margaret Hale filed an eviction proceeding against the Soldals in Illinois state court under the Forcible Entry and Detainer Act; that suit was dismissed on June 2, 1987.2 In August 1987 Terrace Properties filed a second eviction action claiming nonpayment of rent, and the case was set for trial on September 22, 1987.3
Rather than await judgment, Terrace Properties and Hale elected to remove the trailer forcibly on September 4, 1987.4 Hale notified the Cook County Sheriff’s Department that she would remove the home and requested deputies to prevent resistance.5 Two Terrace Properties employees arrived accompanied by Deputy Sheriff O’Neil; they disconnected the sewer, water, and phone lines, tore off the canopy and skirting, and hooked the trailer to a tractor while O’Neil told Soldal he was present to ensure Soldal did not interfere.6
Two additional deputies arrived, and Soldal asked to file a criminal trespass complaint.7 The deputies referred him to Deputy Lieutenant Jones, who remained in Hale’s office for over twenty minutes, consulted a district attorney, and then refused to accept the complaint, stating the dispute was between landlord and tenant and that the removal would proceed.8 Throughout the episode the deputies knew Terrace Properties lacked an eviction order and that its conduct was unlawful, yet they remained while the trailer was pulled free of its moorings and towed onto the street, later to be hauled to neighboring property.9
On September 9 the state judge presiding over the pending eviction case ruled the removal unauthorized and ordered the home returned to the lot, but the trailer had already been badly damaged.10 The Soldals filed suit under 42 U.S.C. § 1983 in federal district court against Terrace Properties, Hale, and Cook County deputy sheriffs, alleging a conspiracy to seize their home in violation of the Fourth and Fourteenth Amendments.11 The district court granted summary judgment to the defendants on the ground that no evidence supported the conspiracy claim or state action.12 The Seventh Circuit panel accepted the existence of state action but held that the removal did not constitute a Fourth Amendment seizure or a due-process deprivation; sitting en banc, the court of appeals reaffirmed that decision, after which the Supreme Court granted certiorari.13
Whether the seizure and removal of the Soldals’ trailer home implicated their Fourth Amendment rights?14
Yes. The Cook County deputy sheriffs’ active assistance in the forcible removal of the Soldals’ trailer home on September 4, 1987, constituted state action that effected a seizure within the meaning of the Fourth Amendment.17 Edward Soldal and his family resided in the trailer on the rented lot.18 Terrace Properties and Hale, without an eviction order, disconnected utilities, tore off the canopy and skirting, hooked the trailer to a tractor, and towed it away while multiple deputies stood by to prevent Soldal from interfering and refused to accept his criminal trespass complaint despite knowing the removal was unlawful.19
This physical dispossession and towing of the home away from its moorings amounted to meaningful interference with the Soldals’ possessory interests in their house.20 The Fourth Amendment’s text expressly protects houses and effects against unreasonable seizures, and precedent establishes that possessory interests receive protection independent of privacy interests, as confirmed by plain-view seizure cases and the distinction between searches and seizures.21 The Seventh Circuit’s contrary view that the Amendment safeguards only privacy and liberty interests therefore fails when applied to these facts.22
The seizure and removal of the Soldals’ trailer home implicated their Fourth Amendment rights.23