State of Tennessee v. Brian Anthony Wiley, M2018-01817-CCA-R3-CD

Defendant Brian Anthony Wiley attended Bonnaroo and bought general admission and a separate car-camping pass; ticket terms warned attendees they were subject to search.
Wiley parked in a dense overnight camping pod, set up an easy-up canopy and sleeping tent adjacent to his vehicle, and used the area as a temporary living space during the festival.
Officers arrested a companion (Trevor Watson) for selling drugs; Watson implicated Wiley and identified his vehicle and campsite; officers located Wiley’s campsite matching the description.
Investigator Sherrill observed multicolored pouches in Wiley’s car like those found on Watson, detained Wiley, called a K-9, the dog alerted to the vehicle, and officers searched the locked car (using recovered keys), uncovering large quantities of drugs and cash.
Wiley moved to suppress, arguing his rented campsite and the vehicle within it were protected as curtilage/temporary home; trial court denied suppression, finding no reasonable expectation of privacy in the campsite and that the automobile exception/probable cause applied; Wiley pled guilty but reserved a certified question of law.
The Tennessee Court of Criminal Appeals affirmed, holding the campsite was not curtilage and the warrantless vehicle search was constitutional.

Issue	Plaintiff's Argument (State)	Defendant's Argument (Wiley)	Held
Whether the car-campsite was curtilage / entitled to a reasonable expectation of privacy	No — ticket terms, the open/dense festival layout, and public exposure negate any reasonable expectation	Yes — campsite (20x20), canopy, tent and vehicle functioned as his temporary home and should be protected	Held: Not curtilage; campsite was ill-defined, open, and exposed; expectation of privacy was not objectively reasonable
Whether the automobile exception justified a warrantless search of the parked vehicle	Yes — Watson’s tip, matching multicolored bags observed, and K-9 alert supplied probable cause to search the vehicle immediately	No — Collins prohibits using the automobile exception to search a vehicle within the curtilage of a home; campsite is analogous to curtilage	Held: Automobile exception applied; vehicle was not within curtilage and officers had probable cause (Watson + observed bags + K-9 alert)
Legality of the K-9 sniff/entry onto campsite and seizure of keys	K-9 sniff of an exposed vehicle and entry onto campsite for investigation were lawful given festival conditions and ticketed consent-to-search notice	K-9 intrusion and officer entry into the rented campsite (and taking of keys) violated Fourth Amendment protections	Held: Officers’ entry and dog sniff did not violate the Fourth Amendment under these facts; subsequent search was lawful (court did not find the key-taking claim dispositive)

Collins v. Virginia, 138 S. Ct. 1663 (automobile-exception search cannot justify warrantless entry into a home’s curtilage)
Florida v. Jardines, 569 U.S. 1 (2013) (property-based trespass test: physically intruding into curtilage can constitute a search)
United States v. Jones, 565 U.S. 400 (2012) (Fourth Amendment analysis includes property-based trespass principles)
Katz v. United States, 389 U.S. 347 (1967) (reasonable-expectations privacy test)
United States v. Dunn, 480 U.S. 294 (1987) (four-factor curtilage analysis)
United States v. Basher, 629 F.3d 1161 (9th Cir. 2011) (campsite outside tent generally not curtilage; dispersed/visible campsites undermine privacy)
State v. Saine, 297 S.W.3d 199 (Tenn. 2009) (automobile-exception framework under Tennessee law)
State v. Christensen, 517 S.W.3d 60 (Tenn. 2017) (Fourth Amendment protects curtilage and recognizes both property- and privacy-based tests)