Coffin v. Brandau, 614 F.3d 1240

Deputy Lutz arrived to serve an Order of Temporary Injunction Against Repeat Violence on Mr. Coffin at the Coffins’ home; the attached garage was fully open.
Brandau arrived shortly after; the deputies stood at the open garage door when the interior garage door opened and the sensor was tripped, causing the door to reopen.
Brandau entered the garage and Coffin emerged; Lutz followed; Brandau stated an intent to arrest Mrs. Coffin for obstructing service.
A struggle ensued in the garage and house; both Coffins were eventually arrested; no warrants were present for the arrest.
Florida law required personal service of restraining orders in repeat-violence cases, and service procedures differ from ordinary process service.
The district court granted summary judgment in favor of the Deputies on both the arrest and garage-entry claims, finding a Fourth Amendment violation but not clearly established law.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Was the warrantless entry into the attached garage a Fourth Amendment violation?	Coffins; the garage is part of the home and should receive Payton-level protection.	Lutz/Brandau; the open garage and curtilage allow police access to knock and serve; not a per se violation.	Yes, entry violated the Fourth Amendment.
Was there probable/arguable probable cause to arrest Ms. Coffin for obstructing service?	Coffin; arrest lacked lawful basis given privacy and service issues.	Deputies had probable/arguable probable cause based on obstruction observed.	Probable/arguable probable cause supported qualified immunity for the arrest.
Were the deputies’ actions during the garage-entry and arrest protected by clearly established law?	Coffins; existing precedents clearly establish garage entry is unlawful.	No clearly established precedent; circumstances were nuanced and context-specific.	Entry violated Fourth Amendment, but law not clearly established; deputies entitled to qualified immunity on the entry claim.

Payton v. New York, 445 U.S. 573 (U.S. 1980) (bright-line rule: no warrantless entry into the home)
Kyllo v. United States, 533 U.S. 27 (U.S. 2001) (garage protections tied to home under Fourth Amendment)
Taylor v. United States, 286 U.S. 1 (U.S. 1932) (garage adjacent to residence protected as part of premises)
Kauz v. United States, 95 F.2d 473 (5th Cir. 1938) (entry into attached garage without warrant violates Fourth Amendment)
Sokolow v. United States, 450 F.2d 324 (5th Cir. 1971) (garage-related search context; factual gaps in open-ness limit precedential value)
United States v. Oaxaca, 233 F.3d 1154 (9th Cir. 2000) (garage protections discussed in context of curtilage and public exposure)
Dunn v. United States, 480 U.S. 294 (U.S. 1987) (curtilage factors; not controlling for open garage but relevant to privacy expectations)
Hope v. Pelzer, 536 U.S. 730 (U.S. 2002) (clearly established standard requires fair warning in context of qualified immunity)