United States v. Fields
456 F.3d 519, 2006 WL 1991567, 2006 U.S. App. LEXIS 18039 (2006)
Rule of Law:
The automobile exception to the Fourth Amendment's warrant requirement permits the warrantless search of a vehicle if there is probable cause to believe it contains contraband, even if the vehicle is not immediately mobile at the time of the search and is located on private property not regularly used by the defendant as a residence.
Facts:
- Officer Michael Neff received information from a confidential source that an individual named 'T-Bone' (identified as Anthony Fields) was selling illegal narcotics out of a duplex in Ft. Worth.
- Neff observed Fields leave an Arlington residence in his black Impala, and another officer, Kevin Turner, subsequently followed Fields to the Ft. Worth duplex described by the confidential source.
- Narcotics officer Jerry Brown observed Fields engage in what he concluded were eight to ten narcotics transactions at the duplex over a 45-60 minute period, involving Fields speaking with car occupants, going into the duplex, returning, and shaking hands with them.
- After the last car left, Brown observed Fields make three trips to his Impala, placing a black bag, an electronic device, and a small cooler inside, before driving away.
- Officers decided to pull Fields over, and Officer Chuck Wiesman, in a marked police car, saw Fields run a stop sign and activated his overhead lights.
- Instead of stopping, Fields accelerated, drove at high speed across two vacant lots, lost control of his car, and crashed the Impala into the side of the same duplex he had just left.
- Fields exited the Impala through the driver's side window and fled on foot, with Wiesman pursuing briefly before returning to the vehicle.
- Officer Brown chased and arrested Fields, who was handcuffed and placed in a patrol car approximately 1.5 to 4 blocks away from the crashed Impala.
Procedural Posture:
- Anthony Fields was charged in a three-count indictment with three drug-related charges.
- A superseding indictment added a fourth count, charging Fields with being a felon in possession of a firearm.
- The Government filed a sentencing enhancement information.
- At a bench conference after jury selection and prior to presenting the indictment to the jury, Fields made an oral motion to suppress evidence, contending a warrantless search of his Impala violated the Fourth Amendment.
- The district court denied the motion to suppress, reasoning the search was valid as a search incident to arrest and because contraband became apparent.
- A jury found Fields guilty on all four counts alleged in the superseding indictment.
- Fields was sentenced to a total aggregate sentence of 300 months imprisonment, a ten-year term of supervised release, and a $100 mandatory special assessment.
- Fields timely filed his notice of appeal with the United States Court of Appeals for the Fifth Circuit.
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Issue:
Does the Fourth Amendment permit the warrantless search of a vehicle under the automobile exception, even if the vehicle is inoperable at the time of the search and located on private property, when police have probable cause to believe it contains contraband and the property is not the defendant's residence?
Opinions:
Majority - Edward C. Prado
Yes, the Fourth Amendment permits such a warrantless search under the automobile exception, as there was probable cause to believe the vehicle contained contraband and the conditions for applying the exception were met. The Fifth Circuit affirmed the district court's denial of Fields' motion to suppress, finding the search of Fields' vehicle valid under the automobile exception to the warrant requirement, despite the district court's previous reliance on the search incident to arrest exception. The court concluded there was probable cause to believe the vehicle contained contraband based on the totality of the circumstances, which included: a confidential informant's tip about drug sales, officers' surveillance observing activity consistent with drug transactions, Fields placing items (a black bag, electronic device, cooler) in his car after these activities, and his unprovoked flight and evasive driving when officers attempted to pull him over (citing Illinois v. Gates and Illinois v. Wardlow). The court addressed Fields' arguments against the automobile exception's applicability. First, regarding the vehicle's mobility, the court rejected Fields' argument that the Impala was not "readily mobile" after crashing. Citing California v. Carney, the court clarified that the exception applies if the vehicle was used as a readily mobile vehicle in the events leading up to the arrest and search, even if it was not immediately mobile at the time of the search. Fields' high-speed chase and crash demonstrated its use as a mobile vehicle, and his disregard for driving regulations did not heighten his privacy interest. Second, concerning the vehicle's location on private property (the duplex), the court stated that Carney applies when a vehicle is "found stationary in a place not regularly used for residential purposes." Evidence indicated that Fields did not use the duplex as a residence but rather for drug sales (minimal furniture, no toiletries, windows covered, boxes of sandwich bags), which diminished any privacy expectations. Furthermore, the car was crashed into the building, not merely parked in a driveway, distinguishing it from cases concerning heightened privacy in a home's curtilage (citing Coolidge v. New Hampshire).
Analysis:
This case clarifies the broad applicability of the automobile exception to the Fourth Amendment's warrant requirement, particularly in scenarios involving a suspect's flight and the aftermath of a vehicle crash. It reinforces that the "readily mobile" aspect of the exception pertains to the vehicle's use in the events leading to the search, not its immediate operational status post-crash. Furthermore, the case underscores that a vehicle's location on private property does not automatically negate the exception if that property is not the defendant's legitimate residence or is not used for residential purposes, thereby limiting heightened privacy claims in such contexts. This expansive interpretation provides law enforcement with significant latitude to conduct warrantless vehicle searches in drug-related investigations following a pursuit.
