United States v. Briscoe, 6:16-cr-10155

On Nov. 18, 2016, officers executed a search warrant for 215 S. Main St. (residence, outbuildings, and vehicles) owned by Michael Kuehn; affidavit described curtilage and vehicles within curtilage but did not mention an RV or the two defendants.
Law enforcement knew before execution that an operable RV was parked ~10–15 feet behind the house and was occupied by Kuehn’s associates (including Briscoe and Hulsey).
After clearing the residence, officers entered and searched the RV (not listed in the warrant or affidavit) and found the defendants asleep plus firearms, ammunition, methamphetamine, drug paraphernalia, cash, and phones; defendants were arrested.
Defendants moved to suppress all evidence from the RV search and evidence obtained after arrest, arguing the RV search exceeded the warrant’s scope.
Government argued the warrant’s authorization to search vehicles on the premises covered the RV; alternatively invoked good-faith reliance on the warrant.
Court ruled the RV search violated the Fourth Amendment because the RV functioned as a separate residence occupied by third parties and required a separate warrant; suppressed evidence and denied the good-faith exception.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the warrant for the residence/outbuildings/vehicles authorized searching the RV	Warrant covered all vehicles on the curtilage; the RV is a vehicle and was on premises and observed by police	RV was a separate, occupied living space not described in the warrant; occupants had a reasonable expectation of privacy	Court: RV search exceeded warrant scope; required separate warrant
Whether the automobile-exception to warrant requirement / RV mobility justified the search	RV is a vehicle and thus subject to vehicle-search rules	RV was functionally a residence (parked, occupied, not readily mobile), so automobile exception doesn't apply	Court: automobile exception not applicable given RV’s residential use and lack of mobility
Whether officers’ knowledge that others occupied the RV affects particularity	Government implied control by premises owner justified inclusion	Officers knew occupants were third-party residents; that knowledge made separate warrant necessary	Court: prior knowledge that third parties lived in RV defeats inclusion under premises warrant
Whether suppression is barred by Leon good-faith exception	Government: officers reasonably relied on facially valid warrant authorizing vehicles	Defendants: officers could not reasonably rely because they knew RV was a separate occupied residence	Court: good-faith exception inapplicable; officers should have obtained a separate warrant

Maryland v. Garrison, 480 U.S. 79 (1987) (particularity requirement; officer’s objectively reasonable mistake may validate search scope in limited circumstances)
California v. Carney, 471 U.S. 386 (1985) (motor home can be treated as a vehicle for Fourth Amendment purposes, but residential use/indicia of residence negate automobile exception)
United States v. Leon, 468 U.S. 897 (1984) (good-faith exception to exclusionary rule for objectively reasonable reliance on a warrant)
United States v. Gottschalk, 915 F.2d 1459 (10th Cir. 1990) (warrant for premises includes vehicles within curtilage when objects of search might be located there)
United States v. Cannon, 264 F.3d 875 (9th Cir. 2001) (separate rental unit on premises required its own warrant where third parties had reasonable expectation of privacy)
United States v. Williamson, 1 F.3d 1134 (10th Cir. 1993) (warrant particularity standard varies with facts and locale)