Automobile exception

Question 1

California v. Carney

Answer 1

Facts
In the case of California v. Carney, the Supreme Court faced the issue of whether the Fourth Amendment was violated by law enforcement agents conducting a warrantless search of a fully mobile motor home located in a public place, based on probable cause. This case originated when Drug Enforcement Agency Agent Robert Williams observed Charles Carney, the respondent, engaging in suspicious activity involving the exchange of marijuana for sexual favors in a Dodge Mini Motor Home. The initial and subsequent searches of the motor home, conducted without a warrant or consent, revealed marijuana and related paraphernalia. Carney was charged with possession of marijuana for sale.

Issue
The central issue before the Supreme Court was whether the warrantless search of Carney’s motor home, justified by probable cause and conducted while the vehicle was parked in a public place, violated the Fourth Amendment.

Holding
The Court held that the search did not violate the Fourth Amendment, reversing the judgment of the California Supreme Court.

Question 2

California v. Acevedo

Answer 2

Facts
In California v. Acevedo, law enforcement officials were informed by a federal drug enforcement agent that a package containing marijuana was addressed to be delivered in Santa Ana, California. After surveillance, Jamie Daza was seen claiming the package and was followed to an apartment. Later, Richard St. George left the apartment with a knapsack containing marijuana, which was searched and seized by officers. Charles Steven Acevedo was observed leaving the same apartment with a paper bag, suspected to contain marijuana, placed in the trunk of his car. Police stopped Acevedo, searched the bag in the trunk without a warrant, and found marijuana. The search of the apartment later on also revealed marijuana, but the case’s focus was on the legality of the search of Acevedo’s car and the bag within it.

Issue
The central legal issue was whether the Fourth Amendment requires law enforcement to obtain a warrant before searching a closed container within a vehicle if they have probable cause to believe the container holds contraband, but not necessarily probable cause to search the entire vehicle.

Holding
The Supreme Court held that the Fourth Amendment does not require police to obtain a warrant to search a closed container within a vehicle if they have probable cause to believe the container holds contraband. This decision effectively allows the search of containers within vehicles without a warrant, provided there is probable cause, aligning the treatment of containers in vehicles with the established automobile exception to the Fourth Amendment’s warrant requirement.

Question 3

Wyoming v. Houghton

Answer 3

Facts
During the early morning hours of July 23, 1995, a Wyoming Highway Patrol officer stopped an automobile for speeding and a faulty brake light. The car contained three passengers: the driver, David Young, his girlfriend, and Sandra K. Houghton, the respondent. Upon noticing a syringe in Young’s pocket, the officer proceeded to search the vehicle for contraband, during which he found a purse belonging to Houghton on the back seat. Houghton initially gave a false name but was identified through her driver’s license found in the purse. The officer discovered methamphetamine and drug paraphernalia both within the purse and a container claimed by Houghton. She was arrested and charged with felony possession of methamphetamine.

Issue
The central question was whether police officers violate the Fourth Amendment when they search a passenger’s personal belongings inside an automobile they have probable cause to believe contains contraband.

Holding
The Supreme Court held that police officers with probable cause to search an automobile for contraband are entitled to inspect passengers’ belongings found in the vehicle that are capable of concealing the object of the search. This decision effectively allows the search of personal belongings within a car without violating the Fourth Amendment, provided there is probable cause.

Question 4

Collins v. Virginia

Answer 4

Facts
Officer Matthew McCall of the Albemarle County Police Department in Virginia observed the driver of an orange and black motorcycle with an extended frame commit a traffic infraction, but the driver eluded him. A similar incident occurred with Officer David Rhodes, who also failed to stop the motorcycle. The officers concluded that the incidents involved the same motorcyclist, likely in possession of Ryan Collins. After discovering photographs on Collins’ Facebook profile featuring the motorcycle at a house, Officer Rhodes located the house, saw the motorcycle covered with a tarp in the driveway, and walked up the driveway without a warrant. He uncovered the motorcycle, confirmed it was stolen, and upon Collins’ return, arrested him. Collins was indicted for receiving stolen property. He moved to suppress the evidence from the warrantless search, arguing it violated the Fourth Amendment. The trial court denied the motion, and Collins was convicted. The decision was affirmed by the Court of Appeals of Virginia and the Supreme Court of Virginia, with the latter holding the search was justified under the automobile exception.
Issue
Does the automobile exception to the Fourth Amendment permit an officer to enter the curtilage of a home without a warrant to search a vehicle parked therein?
Holding
No, the automobile exception does not permit such an action. The U.S. Supreme Court reversed the decision of the Supreme Court of Virginia.