148 N.E.3d 932
Ind.2020Background
- Police obtained a warrant to search Hardin’s home (warrant did not mention vehicles) after surveillance and intercepted communications linked him to meth distribution.
- Officers executed the house warrant, found drug-paraphernalia and ledgers but not the meth; they learned Hardin had recently picked up a large quantity of meth from an associate.
- While officers were searching the home two officers left to look for Hardin; Hardin returned in a truck, was confronted, subdued, and detained inside the house.
- An officer who had been surveilling Hardin searched the truck parked in the home’s driveway (curtilage) and discovered 108 grams of methamphetamine under the driver’s seat.
- Hardin moved to suppress the vehicle evidence (Fourth Amendment and Article 1, §11). Trial court denied suppression; Court of Appeals affirmed in split decision; Indiana Supreme Court granted transfer and affirmed admission of the evidence.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether a general warrant to search a home authorizes searching a vehicle in the home’s curtilage under the Fourth Amendment | Warrant for the premises extends to vehicles in curtilage that are owned/controlled by the resident; officers had indicia of Hardin’s ownership/control | Warrant did not mention vehicles; searching the truck exceeded the warrant’s scope | Search was within scope: vehicle was in curtilage and objectively shown to be owned/controlled by Hardin, so covered by the premises warrant |
| Whether the vehicle search was reasonable under Article 1, §11 (Indiana Constitution) using the Litchfield totality-of-the-circumstances test | High degree of suspicion (warrant + recent tip + house evidence), moderate intrusion, and moderate law‑enforcement need justified the search without a separate warrant | High intrusion into a private vehicle, low immediate need to search (defendant detained and vehicle not going anywhere); officers should have obtained a separate warrant | Search was reasonable under Article 1, §11: balancing Litchfield factors favored the State (high suspicion, moderate intrusion, moderate LE need). Separate opinions concurred/dissented on scope and weight of factors |
| Whether the automobile exception justified the search (alternate argument) | State relied primarily on premises-warrant theory and did not need to invoke automobile exception | Hardin argued warrantless theories should not justify the search | Court did not decide automobile-exception issue because it held the search was authorized by the premises warrant |
Key Cases Cited
- United States v. Ross, 456 U.S. 798 (warrant for fixed premises extends to areas where the object may be found)
- Collins v. Virginia, 138 S. Ct. 1663 (curtilage is part of the home for Fourth Amendment purposes)
- Gottschalk v. United States, 915 F.2d 1459 (premises warrant covers vehicles actually owned or under control of owner/resident or that appear so from objective indicia)
- Litchfield v. State, 824 N.E.2d 356 (Indiana’s three-factor totality-of-the-circumstances test for Article 1, §11 reasonableness)
- Brown v. State, 653 N.E.2d 77 (vehicles viewed as private; warrant preference and caution when searching automobiles without clear exigency)
- Sowers v. State, 724 N.E.2d 588 (premises warrant may extend into the curtilage)
- Garcia v. State, 47 N.E.3d 1196 (assessing police actions in context; totality approach to warrant execution and related searches)