John Coffin v. Stacy Brandau, 2011 U.S. App. LEXIS 11353

Background

Deputies Lutz and Brandau served a Charlotte County restraining order against Mr. Coffin at the Coffins’ open attached garage.
The garage door was fully open when the deputies arrived, exposing the interior.
Brandau tripped the interior sensor in the garage, causing the door to reopen; deputies entered the garage to arrest Ms. Coffin for obstruction of service.
Under Florida law, service of process and restraining orders has specific requirements; personal service and officer involvement are mandated for repeat-violence protections.
Ms. Coffin objected to service, attempted to close the garage door, and a struggle ensued leading to arrests of both Coffins; the district court granted summary judgment in favor of the deputies on qualified-immunity grounds.
The en banc court held that the garage entry violated the Fourth Amendment, but deputies were entitled to qualified immunity because the right was not clearly established.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Was entry into the attached open garage a Fourth Amendment violation?	Coffins: entering the open garage violated Payton’s home-protection rule.	Brandau/Lutz: entry was within permissible curtilage/areas open to public use under totality of the circumstances.	Yes, the entry violated the Fourth Amendment.
Was Ms. Coffin’s arrest for obstruction of service supported by probable or arguable probable cause?	Coffin: arrest lacked probable cause.	Officers had arguable probable cause to arrest for obstructing service.	There was probable or at least arguable probable cause for the arrest.
Were the deputies entitled to qualified immunity for the garage entry?	The entry violated clearly established law.	No clearly established precedent; exigent circumstances and totality of evidence.	No; the right was not clearly established, but qualified immunity shielded the deputies for the entry.
Was the garage-entry rule clearly established law at the time?	Kyllo, Payton and related cases clearly protected attached garages as part of the home.	No single prior opinion clearly controlled the exact open-garage context.	The law was not clearly established; qualified immunity applies to the entry.
Did the en banc court apply an impermissible standard by relying on non-binding authorities?	Dissenters argued that binding standards should be limited to controlling precedents.	Non-binding authorities can inform the reasonable understanding of the law in context.	Court may rely on non-binding authorities to assess reasonable understandings in qualified-immunity analysis.

Key Cases Cited

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 extend to home; thermal imaging case.)
Taylor v. United States, 286 U.S. 1 (U.S. 1932) (garage protected as part of premises; warrant required.)
United States v. Sokolow, 450 F.2d 324 (5th Cir. 1971) (garage entry without a warrant violated Fourth Amendment.)
Kauz v. United States, 95 F.2d 473 (5th Cir. 1938) (garage entry without warrant violated Fourth Amendment.)
Taylor (11th Cir. 2006), 458 F.3d 1201 (11th Cir. 2006) (knocking on residence; front-door approach; not curtilage issue.)
Dunn v. United States, 480 U.S. 294 (U.S. 1987) (curtilage analysis factors for proximity to home.)
Lee v. Ferraro, 284 F.3d 1188 (11th Cir. 2002) (probable cause/arguable probable cause standard in qualified immunity.)
Hope v. Pelzer, 536 U.S. 730 (U.S. 2002) (clearly established standard; reasonableness in qualified immunity.)
Vinyard v. Wilson, 311 F.3d 1340 (11th Cir. 2002) (obvious-clarity standard in qualified immunity.)