721 F.3d 952
8th Cir.2013Background
- Methias was indicted on one count of conspiracy to manufacture marijuana; he pled guilty conditioned on challenging the district court’s denial of his suppression motion.
- Officer Murray received an anonymous tip about marijuana in a backyard on the 300 block of South Jefferson Street, Mount Pleasant, leading him to Mathias’s residence.
- The backyard was enclosed by a tall wooden fence; a neighboring property line placement meant Murray walked on a narrow grass strip about eighteen inches onto Mathias’s property.
- From that strip, Murray looked through gaps in the fence and observed potted marijuana plants in the backyard, prompting a warrant for Mathias, his wife, and their residence.
- The district court denied the suppression motion, ruling the strip was an open field; Mathias pleaded guilty, preserving his right to appeal the suppression ruling.
- The Eighth Circuit affirmed the denial of the suppression motion, holding the strip was an open field and Murray’s observations were permissible.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the strip of land is curtilage or open field | United States contends the strip is open field, not curtilage | Mathias argues the strip is curtilage with a reasonable expectation of privacy | Strip deemed open field; no Fourth Amendment curtilage protection |
| Whether Murray’s observations from the strip violated the Fourth Amendment | United States argues no trespass or privacy violation occurred | Mathias asserts trespass and privacy interests were implicated by observations | Observations from an open field do not constitute a Fourth Amendment violation; trespass not constitutionally significant; no reasonable privacy expectation breached |
Key Cases Cited
- United States v. Dunn, 480 U.S. 294 (Supreme Court, 1987) (open fields doctrine; proximity and enclosure factors in curtilage analysis)
- California v. Ciraolo, 476 U.S. 207 (Supreme Court, 1986) (public vantage point may observe what is knowingly exposed to the public)
- United States v. Jones, 132 S. Ct. 945 (Supreme Court, 2012) (trespassory search requires a trespass into a protected area; layers of Fourth Amendment search theories)
- Oliver v. United States, 466 U.S. 170 (Supreme Court, 1984) (open fields doctrine; no privacy interest in open fields)
- United States v. Wells, 648 F.3d 671 (8th Cir., 2011) (curtilage determination reviewed for clear error; open field doctrine applies)