Collins v. Virginia
|Collins v. Virginia|
|Argued January 9, 2018|
Decided May 29, 2018
|Full case name||Ray Austin Collins v. Virginia|
|Citations||584 U.S. (more)|
138 S. Ct. 1663; 201 L. Ed. 2d 9
|Prior||Collins v. Commonwealth, 292 Va. 486, 790 S.E.2d 611 (2016); cert. granted, 138 S. Ct. 53 (2017).|
|The Fourth Amendment's motor vehicle exception for a warrantless search based on reasonable cause does not apply to vehicles stored within a person's home or its curtilage|
|Majority||Sotomayor, joined by Roberts, Kennedy, Thomas, Ginsburg, Breyer, Kagan, Gorsuch|
Collins v. Virginia, No. 16-1027, 584 U.S. ___ (2018), was a case before the Supreme Court of the United States involving search and seizure. At issue was whether the Fourth Amendment's automobile exception permits a police officer, uninvited and without a warrant, to enter private property, approach a house, and search a vehicle parked a few feet from the house otherwise visible from off the property. In an 8–1 judgement, the Supreme Court ruled that the automobile exception does not apply to vehicles parked within the home or curtilage of a private homeowner.
Facts and prior history
In Virginia, Albemarle County officer David Rhodes observed from the street what appeared to be a motorcycle with a distinctive appearance under a tarp parked on the property of a home where Charlottesville resident Ryan Austin Collins was staying; Rhodes had recognized the colors from a previous high-speed chase two months earlier where the rider of the motorcycle had eluded him. Rhodes found photographs of the motorcycle on Collins' Facebook pages and which appeared to be taken from where he had seen it parked, which was located near the home in an area that was walled on one side by the home, and on two sides by a short brick wall. With this as reasonable cause, Rhodes entered the property in the absence of Collins and without a warrant, lifted the tarp, observed the VIN and took additional photographs, and determined that the bike was stolen. When Collins returned to the home, Rhodes arrested him on charges of stealing the bike, and the key to the motorcycle was discovered in Collins' possession on arrest. Collins denied owning or having ridden the bike in months.
During trial court, Collins argued that the police illegally entered the property to search as the vehicle was parked with the walled area that he considered the curtilage of the home, a violation under the Fourth Amendment, and sought to void the evidence taken by Rhodes' search. The state argued that the previous chase and two photos Collins had posted on Facebook of himself and the motorcycle were sufficient cause. The trial court agreed with the state that Rhodes has reasonable cause to search under the tarp; this ruling was upheld both in the state's appeal courts and in the Virginia Supreme Court, with the latter affirming that Rhodes' search was proper under the motor vehicle exception to the Fourth Amendment defined through past Supreme Court cases, which allows for warrantless searches for automobiles where there is reasonable cause.
Latest developments and next steps
Collins petitioned the Supreme Court for writ of certiorari on whether the Fourth Amendment protects his rights of privacy for the area a few feet from the boundaries of his home. The Supreme Court agreed in September 2017 to hear the case. The Court heard oral arguments on January 9, 2018.
In oral arguments, the Justices discussed the curtilage, the homeowner's expectation of privacy there, and the officer's right to enter on the property. They discussed the officer's right to lift the tarp, which was potentially a search. Further, they discussed the difference between an automobile, which is potentially mobile and creates an exigent circumstance for search, with drugs or papers, which are immobile. The discussion devolved into a discussion of the differences between garage, carport, driveway, and street. Justice Ginsburg pointed out that protection of the garage but not a driveway burdens people who cannot afford a garage.
The Court issued its ruling on May 29, 2018, reversing and remanding the case back to lower courts. The Court ruled 8–1 that the automobile exemption does not include the home or curtilage, and that vehicles that are stored within the home's curtilage cannot be searched without warrant. Justice Sonia Sotomayor wrote the majority opinion, joined by all but Justice Samuel Alito; Justice Clarence Thomas also wrote a concurring opinion, agreeing with the decision but questioning if they had the right to force states to suppress incriminating evidence that was obtained unconstitutionally, as this would be akin to forcing states to follow the federal exclusionary rule.
Alito wrote the sole dissenting opinion, arguing that whether the motorcycle was parked in the curtilage or not was unnecessary given that the motorcycle was within plain view, and thus there was a reasonable cause for the officer to examine the vehicle.
- Chappell, Hugh (September 28, 2017). "Supreme Court Adds More Cases To 2017-2018 Term, Including Union Dispute". NPR. Retrieved 28 September 2017.
- Collins v. Virginia, No. 16-1027, 584 U.S. ___ (2018).
- Sherman, Mark (May 29, 2018). "Supreme Court limits warrantless vehicle searches near homes". Associated Press. Retrieved May 29, 2018.
- Barnes, Robert (May 29, 2018). "Supreme Court says warrants needed to search vehicles on private property". The Washington Post. Retrieved May 29, 2018.
- Collins v. Commonwealth, 292 Va. 486, 790 S.E.2d 611 (2016).
- "Collins v. Virginia" (PDF). Supreme Court of the United States. January 9, 2018. Retrieved 13 January 2018.