Byrd v. United States
| Byrd v. United States | |
|---|---|
 | |
| Argued January 9, 2018 Decided May 14, 2018 | |
| Full case name | Terrence Byrd, Petitioner v. United States |
| Docket no. | 16-1371 |
| Citations | 584 U.S. ___ (more) 138 S. Ct. 1518; 200 L. Ed. 2d 805 |
| Case history | |
| Prior | United States v. Byrd, 679 F. App'x 146 (3d Cir. 2017); cert. granted, 138 S. Ct. 54 (2017). |
| Holding | |
| Drivers of rental cars have rights protecting them from unconstitutional searches by police, even if they are not listed on the rental agreement. | |
| Court membership | |
| |
| Case opinions | |
| Majority | Kennedy, joined by unanimous |
| Concurrence | Thomas, joined by Gorsuch |
| Concurrence | Alito |
Byrd v. United States, 584 U.S. ___ (2018), was a United States Supreme Court case in which the Court held drivers of rental cars have rights protecting them from unconstitutional searches by police, even if they are not listed on the rental agreement.[1]
Background
In mid-2014 Terrance Byrd was driving a rental car along a Pennsylvania highway. The car had been rented by his long-time girlfriend and driven with her consent, though Byrd's name was not listed as an authorized driver of the car on the rental agreement. A state trooper, David Long, pulled Byrd over for a small traffic violation, and Byrd's mannerisms raised Long's suspicions; further checks of Byrd's history revealed past criminal convictions and an arrest warrant in New Jersey. As Byrd was not listed on the rental agreement, Long initiated a search of the car without Byrd's consent and found several pounds of heroin and body armor in the trunk. Byrd was arrested and tried on federal drug charges in the United States District Court for the Middle District of Pennsylvania. Byrd's lawyers attempted to have the search of the car dismissed as evidence, as it violated Byrd's rights against unreasonable searches under the Fourth Amendment defined under the motor vehicle exception, but the judge refused to clear this, since by the rental contract, Byrd was not an authorized driver and did not have this right. Byrd pleaded guilty to the charges but leaving the option to appeal the conviction. He was sentenced to ten years in prison.[2]
Byrd's lawyers appealed to the United States Court of Appeals for the Third Circuit, which was heard and reviewed in late 2016. The Third Circuit acknowledged there was a split among the Circuit Courts as the right of privacy related to rental cars, and previous cases within the Third Circuit had ruled that such drivers do not have expectations of privacy. The Third Circuit upheld the District Court's decision on this basis.[2]
Supreme Court
Byrd's lawyers submitted a petition for writ of certiorari with the Supreme Court in March 2017. The petition focused on the question that while there is a well-established expectation of privacy for a driver of a car, is that expectation nullified in the case of a rental car where the driver is not on the rental contract.[3] The Court agreed the hear the case in September 2017.
Oral arguments were heard on January 9, 2018; oral arguments in another Fourth Amendment case relating to vehicles and rights to privacy, Collins v. Virginia, was heard the same day.
The Supreme Court issued its ruling on May 14, 2018. In the unanimous decision favoring Byrd, Justice Anthony Kennedy wrote that "The mere fact that a driver in lawful possession or control of a rental car is not listed on the rental agreement will not defeat his or her otherwise reasonable expectation of privacy".[4] Kennedy added that there can be numerous reasons why a driver unlisted on a rental contract may need to drive the rental car, and that the government had not shown that whether the simple breach of the rental contract would affect the expectation of privacy.[5] Kennedy's decision states that there remained two issues which the Supreme Court remanded back to the lower courts: whether Long had probable cause to search the car in the first place, and whether Byrd "intentionally used a third party as a straw man in a calculated plan to mislead the rental company from the very outset, all to aid him in committing a crime".[4]
References
- ^ Byrd v. United States, No. 16-1371, 584 U.S. ___ (2018).
- ^ a b Liptak, Adam (January 1, 2018). "Pulled Over in a Rental Car, With Heroin in the Trunk". The New York Times. Retrieved May 14, 2018.
- ^ "Petition For A Writ Of Certiorari" (PDF). SCOTUS Blog. May 11, 2017. Retrieved May 14, 2018.
- ^ a b Liptak, Adam (May 14, 2018). "Supreme Court Rules for Death Row Inmate Betrayed by His Lawyer". The New York Times. Retrieved May 14, 2018.
- ^ Stohr, Greg (May 14, 2018). "U.S. Supreme Court Limits Police Rental-Car Searches". Bloomberg Businessweek. Retrieved May 14, 2018.
External links
- Text of Byrd v. United States, 584 U.S. ___ (2018) is available from: Justia Oyez (oral argument audio) Supreme Court (slip opinion)