Byrd v. United States, 138 S. Ct. 1518

Background

Terrence Byrd drove a rental car alone though he was not listed as an authorized driver on the rental agreement signed by Latasha Reed; Reed gave Byrd the keys after renting.
Pennsylvania troopers stopped Byrd for a traffic suspicion, learned the car was rented and Byrd was not listed, and told him they did not need his consent to search the vehicle.
During the stop officers searched the passenger compartment and trunk, found body armor and 49 bricks of heroin, and Byrd was charged in federal court; he moved to suppress the evidence.
District Court and Third Circuit denied suppression, concluding Byrd lacked a reasonable expectation of privacy because he was not an authorized driver; the courts did not decide probable cause.
The Supreme Court granted certiorari to decide whether an unauthorized driver who is in lawful possession and control of a rental car has a Fourth Amendment expectation of privacy.

Issues

Issue	Byrd's Argument	United States' Argument	Held
Whether an unauthorized driver in lawful possession/control of a rental car has a Fourth Amendment expectation of privacy	Byrd: possession and control (sole occupant/driver) create a reasonable expectation of privacy	Government: lack of authorization on rental agreement per se eliminates any privacy expectation	Held: Mere absence from rental agreement does not automatically defeat expectation of privacy; lawful possession/control generally supports a privacy interest
Whether breach of rental agreement (unauthorized driving) nullifies privacy interests	Byrd: breach is a private-contract issue and does not eliminate Fourth Amendment rights	Government: the contract breach (unauthorized driver) renders agreement/coverage void and destroys any privacy interest	Held: Contract breach alone does not meaningfully negate a reasonable expectation of privacy; rental terms allocate risk but do not control Fourth Amendment analysis
Whether wrongful or fraudulent procurement of the rental car equates to possessing the car like a thief (no privacy interest)	Byrd: did not raise detailed second-bailee/property arguments below; factual dispute about intent and procurement	Government: alleges Byrd used Reed as a strawman to procure car to commit crime, likening it to theft or fraud, which would defeat privacy claim	Held: Court declines to decide; remanded for factual development and consideration whether fraudulent procurement should bar the claim
Whether probable cause justified the search even if Byrd had standing	Byrd: challenged search as unlawful; probable-cause issue contested below	Government: argues probable cause existed (e.g., Byrd admitted marijuana) and would justify warrantless search under automobile exception	Held: Not decided by Supreme Court; remanded so lower courts may address probable cause in the first instance if they choose

Key Cases Cited

Rakas v. Illinois, 439 U.S. 128 (explains legitimate expectation of privacy must have source outside the Fourth Amendment and links property/exclusion rights to privacy)
Jones v. United States, 362 U.S. 257 (recognizes privacy interest from possession and control akin to dominion over premises)
Katz v. United States, 389 U.S. 347 (establishes reasonable expectation of privacy test)
Florida v. Jardines, 569 U.S. 1 (clarifies that Katz test supplements, not displaces, property-based Fourth Amendment analysis)
Chimel v. California, 395 U.S. 752 (context on Fourth Amendment protections against undue police rummaging)
Arizona v. Gant, 556 U.S. 332 (addresses limits on vehicle searches incident to arrest and concerns about unbridled police discretion)
California v. Acevedo, 500 U.S. 565 (automobile exception to warrant requirement)
Minnesota v. Olson, 495 U.S. 91 (recognizes expectation of privacy for overnight guests without property ownership)
Mancusi v. DeForte, 392 U.S. 364 (Fourth Amendment rights need not be grounded in common-law property interests)
Delaware v. Prouse, 440 U.S. 648 (discusses diminished expectation of privacy in automobiles)