United States v. Jones, 893 F.3d 66

Jones was investigated for months by DEA task force and Hartford PD for alleged crack distribution; prior arrest and tips linked him to 232 Westland St.
Surveillance showed Jones driving and parking a Dodge Magnum in the rear shared driveway of a multi‑family building; others left that address in another car from which officers recovered crack and identified Jones as the supplier.
Officers arrested Jones nearby, found large amounts of cash on him and in an associated vehicle; a tow truck had attempted to remove the Dodge Magnum at Jones's request and later returned it to the rear lot.
After obtaining a warrant for the apartments and recovering drugs, ammo, and paraphernalia from the second‑floor unit, Officer Campbell peered through the Magnum’s rear window, observed a box of ammunition, and officers performed a warrantless search of the vehicle recovering drugs, guns, and ammo.
Jones moved to suppress the vehicle evidence; the district court denied suppression, he was convicted on seven drug and firearms counts, and appealed arguing lack of probable cause, heightened privacy (curtilage), absence of exigency, among other claims.

Issue	Jones's Argument	Government's Argument	Held
Probable cause to search vehicle	Officers lacked probable cause to believe the Magnum contained contraband	Officers had multiple corroborating facts (surveillance, recovered drugs from associate, statements, cash, tow request, apartment search results, and observed ammo)	Probable cause existed; search justified
Expectation of privacy / curtilage	Magnum was parked in lot within his home's curtilage, so higher privacy protection applied	Lot was a shared/common area, not within curtilage or exclusive control	No reasonable expectation of privacy; curtilage claim rejected
Applicability of automobile exception / exigency	No exigent circumstances justified warrantless vehicle search after suspects were in custody and area secured	Automobile exception does not require separate exigency when car is readily mobile and probable cause exists	Automobile exception applies; no separate exigency required
Admission of vehicle evidence at trial	Evidence from warrantless search should be suppressed	Admission appropriate given probable cause and reduced expectation of privacy in shared parking	Admission affirmed; conviction and sentence affirmed

Maryland v. Dyson, 527 U.S. 465 (1999) (automobile exception permits warrantless vehicle searches when vehicle is mobile and probable cause exists)
California v. Carney, 471 U.S. 386 (1985) (reduced expectation of privacy in vehicles due to pervasive regulation and mobility)
Collins v. Virginia, 138 S. Ct. 1663 (2018) (automobile exception does not permit warrantless entry into home curtilage to search vehicle)
United States v. Gaskin, 364 F.3d 438 (2d Cir. 2004) (definition of probable cause for searches)
United States v. Navas, 597 F.3d 492 (2d Cir. 2010) (discussion of rationales for automobile exception)
United States v. Dunn, 480 U.S. 294 (1987) (test for whether an area is within home curtilage)
United States v. Fields, 113 F.3d 313 (2d Cir. 1997) (no expectation of privacy in common areas of multi‑tenant buildings)
United States v. Holland, 755 F.2d 253 (2d Cir. 1985) (common halls and lobbies not within tenant's zone of privacy)