The United States Supreme Court (SCOTUS) ruled in May that the automobile exception to the U.S. Constitution’s Fourth Amendment protection against unlawful searches and seizures forbids a warrantless search of a motorcycle parked in a driveway. The 8-1 ruling in Collins v. Virginia held that the automobile exception to the Fourth Amendment’s warrant requirement did not apply in the Collins case because the officer had intruded on the home’s curtilage. A home’s curtilage is the area adjacent to the residence into which the activity of home life spills out.


The Facts of the Case


Albemarle County, Virginia law enforcement officers unsuccessfully attempted to pull over a motorcyclist for traffic violations on two separate occasions. Each time the driver was able to escape the authorities. Police officers later learned that the motorcycle they were chasing was stolen. A suspect was identified based on a photograph that was posted on social media of the motorcycle parked in front of his girlfriend’s home. As a result of the Facebook posting of the motorcycle, a law enforcement officer drove to the location and removed the tarp that was covering the bike. The officer had not been invited onto the property nor did he have a warrant to search the property. The suspect was later arrested and told law enforcement that he purchased the motorcycle without a title. The suspect was charged with receiving stolen property.


The Court Rulings


The Virginia Supreme Court held that the police officer’s search was proper because there was probable cause and a warrant was not necessary under the automobile exception to the Fourth Amendment. First established by the SCOTUS in 1925 in Carroll v. United States, the automobile exception to the Fourth Amendment’s protections against unreasonable searches and seizures allows a law enforcement officer to search a vehicle without a warrant as long as there is probable cause to believe that evidence or contraband is located in the vehicle.


The United States Supreme Court reversed the decision, holding that the automobile exception did not apply. The reasoning was that the officer had intruded on the home’s curtilage. Writing the majority opinion for the Court, Justice Sotomayor noted that the automobile exception is based on the concept that vehicles are both extensively regulated and mobile; the exception accounts for the government’s interest in an expedient search of the vehicle. The exception does not, according to the SCOTUS, account for the “distinct privacy interests in one’s home or curtilage.” Justice Samuel Alito dissented, noting the search was entirely reasonable and did not constitute an unreasonable search and seizure.