Doyle Burton v. State of Indiana (mem. dec.)
49A02-1702-CR-220
| Ind. Ct. App. | Nov 9, 2017Background
- On October 16, 2016, a maroon Toyota minivan rear-ended Mark Ford; the van fled but later was found parked in an apartment complex with heavy front-end damage.
- Officers located the vehicle, recovered its registration from the glove box, and went to the apartment listed on the mail; Doyle Burton came out and admitted driving and drinking; Ford identified Burton as the driver.
- Burton was charged with OWI (multiple counts) and driving without having received a license.
- Burton moved to suppress evidence seized from his vehicle (warrantless search); the trial court denied the motion, concluding the search fell within the automobile exception.
- Burton appealed, arguing the warrantless search was unlawful because the vehicle was not readily mobile and was parked at his residence; the Court of Appeals reviewed the denial under the Fourth Amendment.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the warrantless search of the vehicle was lawful under the automobile exception | State: officers had probable cause to believe the vehicle contained evidence of a hit-and-run and the registration, justifying a warrantless search | Burton: vehicle was not readily mobile and was parked at his apartment, so automobile exception shouldn’t apply | Court: automobile exception applies—probable cause existed and vehicle was readily mobile; parking in an apartment lot did not make it curtilage |
Key Cases Cited
- Renzulli v. State, 958 N.E.2d 1143 (Ind. 2011) (standard of review for suppression rulings)
- Osborne v. State, 63 N.E.3d 329 (Ind. 2016) (State bears burden to show warrant exception)
- Hobbs v. State, 933 N.E.2d 1281 (Ind. 2010) (automobile exception and diminished privacy in vehicles)
- Meister v. State, 933 N.E.2d 875 (Ind. 2010) (probable cause that vehicle contains evidence permits warrantless search)
- California v. Acevedo, 500 U.S. 565 (1991) (holding probable cause to search vehicle’s contents allows warrantless search)
- Pennsylvania v. Labron, 518 U.S. 938 (1996) (if car is readily mobile and probable cause exists, police may search without more)