State v. Woodrome, 407 S.W.3d 702

Background

Police went to an RV park to execute arrest warrants for Woodrome and Shankle after confirming the pair lived in an RV on a rented lot. No one initially answered when officers knocked on the RV.
While outside the RV, Detective Botta read a VIN on the fifth-wheel and learned the trailer had been reported stolen; officers observed other indicia of theft on a construction truck and a Pace trailer.
Shankle was later arrested on the premises; Woodrome fled on foot after refusing to stop his motorcycle and was apprehended days or weeks later.
Officers seized the vehicles and later searched them at tow lots; searches produced incriminating evidence admitted at trial.
Woodrome moved to suppress, arguing the searches of the vehicles on his rented RV lot violated the Fourth Amendment; the trial court denied the motion and convicted him on three counts of receiving stolen property (acquitted on one count).
On appeal, the court considered whether Woodrome had a reasonable expectation of privacy in the stolen RV (and surrounding lot/curtilage) sufficient to challenge the searches.

Issues

Issue	Woodrome's Argument	State's Argument	Held
Whether Woodrome had a reasonable expectation of privacy in the RV and surrounding lot	He rented the lot and therefore had a privacy interest in the lot/curtilage and property on it	The RV was stolen; one cannot reasonably expect privacy in stolen property or an open lot/field	No expectation of privacy in the stolen RV or lot; no standing to suppress
Whether officers’ inspection of VINs/vehicles while executing arrest warrants exceeded lawful scope	Officers should have ceased investigation when owner said defendants weren’t present	Officers had authority to attempt arrest at the dwelling and to observe things in plain view while executing the warrant	Officers properly approached, observed VINs/plain-view indicia, and ran VINs while attempting to execute warrants
Whether evidence seized from, and searches of, seized vehicles should be suppressed as unconstitutional	Evidence obtained from vehicles on the rented lot was product of an unlawful search/seizure	Because defendant lacked Fourth Amendment standing, suppression is not warranted	Trial court did not err admitting the evidence; suppression denied
Applicability of curtilage/open-fields doctrines to mobile/stolen dwellings	Curtilage protection attaches to a dwelling and thus to the lot around an RV	Curtilage protection depends on a legitimate privacy interest; stolen dwelling does not confer such interest; open-lot doctrine applies	Curtilage did not extend Fourth Amendment protection here because the RV was stolen; open-fields principles apply to lots

Key Cases Cited

Payton v. New York, 445 U.S. 573 (warrant for arrest permits entry into suspect’s dwelling when reason to believe suspect is inside)
Rakas v. Illinois, 439 U.S. 128 (Fourth Amendment standing requires legitimate expectation of privacy)
Hester v. United States, 265 U.S. 57 (open-fields doctrine: Fourth Amendment does not protect open fields)
Smith v. Maryland, 442 U.S. 735 (two-part expectation-of-privacy test: subjective and societally reasonable)
Soldal v. Cook Cnty., 506 U.S. 56 (Fourth Amendment protects people, not places; standing analysis tied to privacy expectations)
United States v. Davis, 288 F.3d 359 (warrant-based arrest authority extends to trailer property where suspect lives)
United States v. Caymen, 404 F.3d 1196 (no reasonable expectation of privacy in stolen property)
United States v. Tropiano, 50 F.3d 157 (same: stolen property and expectation of privacy)
State v. Ramires, 152 S.W.3d 385 (Missouri: standing to suppress requires legitimate expectation of privacy)
State v. Walters, 636 S.W.2d 122 (defendant cannot claim Fourth Amendment protection in another’s/stolen property)