Collins v. Virginia
138 S. Ct. 1663
| SCOTUS | 2018Background
- Officer Rhodes linked an orange-and-black extended-frame motorcycle to Ryan Collins after two separate high-speed incidents and Facebook photos.
- Rhodes drove to the address (Collins stayed there periodically), parked on the street, and observed a tarp-covered motorcycle in the top portion of the driveway.
- Without a warrant, Rhodes walked onto the property, uncovered the tarp, viewed the motorcycle, ran its VIN/plate, photographed it, replaced the tarp, and left to await Collins.
- Collins was arrested after admitting ownership; he moved to suppress evidence from the warrantless search of the motorcycle.
- Virginia courts upheld the search under the automobile exception; the U.S. Supreme Court granted certiorari and reversed.
Issues
| Issue | Collins' Argument | Virginia's Argument | Held |
|---|---|---|---|
| Whether the automobile exception permits warrantless entry onto a home’s curtilage to search a vehicle | Automobile exception does not justify intrusion onto curtilage; home/curtilage protections dominate | Automobile exception is categorical and allows warrantless vehicle searches anywhere, including curtilage | No: automobile exception does not permit warrantless entry into home or curtilage to search a vehicle |
| Whether the driveway area where the motorcycle sat is curtilage | That enclosure is adjacent to the house and used for home life; thus it's curtilage | Area is accessible/visible from street; not protected to the same degree | The top portion of the driveway was curtilage and thus entitled to Fourth Amendment protection |
| Whether precedents (e.g., Scher, Labron) authorize warrantless intrusion into curtilage to search vehicles | Precedents do not support expanding automobile exception into homes/curtilage | Scher and Labron demonstrate that vehicle searches in driveways/near homes can be warrantless | Scher and Labron do not control; neither authorizes categorical carve‑outs permitting curtilage entry without a warrant |
| Whether the evidence should nevertheless be admissible under other exceptions (e.g., exigent circumstances) | Suppression required unless another exception applies; remand appropriate to consider other doctrines | Evidence lawful under automobile exception (or other exigencies argued below) | Court remanded to allow Virginia courts to consider other justifications (e.g., exigent circumstances) but rejected automobile-exception justification |
Key Cases Cited
- Carroll v. United States, 267 U.S. 132 (automobile exception originates from vehicles’ ready mobility)
- California v. Carney, 471 U.S. 386 (automobile exception rationale and limits)
- Florida v. Jardines, 569 U.S. 1 (curtilage is part of the home for Fourth Amendment purposes)
- Oliver v. United States, 466 U.S. 170 (definition and protection of curtilage)
- Horton v. California, 496 U.S. 128 (plain‑view seizure requires lawful access to the object)
- Payton v. New York, 445 U.S. 573 (warrant required for home entry to effect arrest absent exception)
- South Dakota v. Opperman, 428 U.S. 364 (vehicles subject to pervasive regulation; related automobile exception rationale)
- Scher v. United States, 305 U.S. 251 (factbound; does not establish a rule permitting curtilage entry without a warrant)