Collins v. Virginia

In Collins v. Virginia (Argued January 9, 2018 - Decided May 29, 2018 ), the USSC held that the scope of the automobile exception extends no further than the automobile itself; its proposed "expansion would undervalue the core Fourth Amendment protection afforded to the home and its curtilage and untether the exception from its justifications."

JUSTICE SOTOMAYOR delivered the opinion of the Court. This case presents the question whether the automobile exception to the Fourth Amendment permits a police officer, uninvited and without a warrant, to enter the curtilage of a home in order to search a vehicle parked therein. It does not.

The key to this decision is balance; compare the government interest in law enforcement against the sanctity of the home.

The essential facts of the case are simple: police made a warrantless entry into the curtilage of a home seeking and then collecting evidence related to a collection of traffic violations, and possibly a stolen motorcycle that had been used to commit those violations.

Two aspects of 4th Amendment law are involved:

1)  Consider that, after the person himself, his house is the next explicitly listed object protected from intrusion by the government.  His effects, even if considered instrumentalities of a crime, enjoy a lower standard.  Remember, the curtilage of a home enjoys the same intrusion protections as the home itself.  The fact that the suspect motorcycle could be seen from a legal vantage point still did not justify the physical intrusion into the curtilage.  For a good discussion of the privacy of a home and its curtilage, see Florida v. Jardines.

2)  In 1925, the USSC created the infamous automobile exception to the warrant requirement, stating that if there was probable cause to believe contraband was in a car (in the Carroll case, alcohol being imported from Canada), due to its inherent mobility, the exigency of the moment weighed in favor of an exception to requiring a warrant before conducting a search of the car.

In the instant case, there was no exigency to justify the warrantless intrusions on both the parked motorcycle and, in particular, the curtilage of the home; and in a 8-to-1 decision, the USSC ruled the privacy of the home outweighed the government benefit allowed by the 1925 Carroll automobile exception.