Collins v. Virginia
138 S. Ct. 1663 (2018)
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Rule of Law:
The automobile exception to the Fourth Amendment's warrant requirement does not permit a police officer to enter the curtilage of a home to search a vehicle parked therein. The exception's scope is limited to the vehicle itself and does not confer a lawful right of access to constitutionally protected property.
Facts:
- After two separate incidents where an orange and black motorcycle eluded police, officers began an investigation.
- The investigation led them to suspect the motorcycle was stolen and in the possession of Ryan Collins.
- Officer David Rhodes discovered photos on Collins' Facebook profile showing the motorcycle parked in the driveway of a specific house.
- Rhodes went to the house and, from the street, saw what appeared to be the motorcycle covered by a white tarp, parked in an enclosed portion of the driveway adjacent to the house.
- Without a warrant, Officer Rhodes walked up the driveway onto the property, removed the tarp from the motorcycle, and ran the license plate and VIN.
- The search confirmed the motorcycle was stolen.
- When Collins returned to the residence, Rhodes approached him, and Collins admitted the motorcycle was his.
- Officer Rhodes then arrested Collins.
Procedural Posture:
- Ryan Collins was indicted by a Virginia grand jury for receiving stolen property.
- In the state trial court, Collins filed a pretrial motion to suppress the evidence from the motorcycle search, arguing it violated the Fourth Amendment.
- The trial court denied the motion, and Collins was convicted.
- Collins appealed his conviction to the Court of Appeals of Virginia, an intermediate appellate court.
- The Court of Appeals of Virginia affirmed the trial court's judgment.
- Collins then appealed to the Supreme Court of Virginia, the state's highest court.
- The Supreme Court of Virginia affirmed the conviction, holding that the warrantless search was justified under the Fourth Amendment's automobile exception.
- The U.S. Supreme Court granted Collins's petition for a writ of certiorari.
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Issue:
Does the Fourth Amendment's automobile exception permit a police officer, without a warrant, to enter the curtilage of a home to search a vehicle parked therein?
Opinions:
Majority - Justice Sotomayor
No. The automobile exception does not permit a police officer, without a warrant, to enter the curtilage of a home to search a vehicle parked therein. The curtilage is considered part of the home for Fourth Amendment purposes and is afforded the highest protection against unreasonable searches. The rationales for the automobile exception—a vehicle's ready mobility and the pervasive regulation of vehicles—are specific to the vehicle itself and do not justify an intrusion into the separate, constitutionally protected area of the home or its curtilage. Just as officers need a lawful right of access to seize an item in plain view, they must also have a lawful right of access to a vehicle to search it under the automobile exception; the exception itself does not provide that right of access to private property.
Concurring - Justice Thomas
Yes, a Fourth Amendment violation occurred, but the Court's authority to impose the exclusionary rule as a remedy on the states is questionable. While agreeing that the warrantless search of the curtilage was unreasonable, this opinion argues that the exclusionary rule is not a constitutional requirement but a judicially created, prudential doctrine. As a form of federal common law, it should not be binding on the states, and its application distorts substantive Fourth Amendment law. The historical remedies for unconstitutional searches were tort suits and self-help, not the suppression of evidence.
Dissenting - Justice Alito
Yes. The search was reasonable and should be permitted under the Fourth Amendment. The officer's actions were entirely reasonable given he had probable cause to believe the motorcycle was stolen and involved in dangerous crimes. The key rationale for the automobile exception—mobility—was fully present, as the motorcycle could have been moved in seconds. The officer's brief walk up the driveway constituted a negligible intrusion on privacy and did not cause any harm. The Court's rigid application of the curtilage doctrine creates an unreasonable result that is inconsistent with the Fourth Amendment's hallmark of reasonableness.
Analysis:
This decision significantly clarifies and limits the scope of the automobile exception, reinforcing the sanctity of the home and its curtilage under the Fourth Amendment. The Court established that the exception is not a master key that allows police to enter constitutionally protected areas to access a vehicle. This ruling forces law enforcement to distinguish between vehicles in public places and those on private, protected property, requiring a warrant or a separate warrant exception to enter the curtilage. The decision strengthens privacy protections for individuals, particularly those who park their vehicles in driveways or carports near their homes, by preventing the automobile exception from eroding the traditional protections afforded to residential property.
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