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Collins v. Virginia

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Supreme Court of the United States
Collins v. Virginia
Term: 2017
Important Dates
Argument: January 9, 2018
Decided: May 29, 2018
Outcome
Supreme Court of Virginia reversed
Vote
8 - 1 to reverse
Majority
Chief Justice John G. Roberts • Anthony Kennedy • Clarence Thomas • Ruth Bader Ginsburg • Stephen Breyer • Sonia Sotomayor • Elena Kagan • Neil Gorsuch
Concurring
Clarence Thomas
Dissenting
Samuel Alito


Collins v. Virginia is a case argued during the October 2017 term of the U.S. Supreme Court. Argument in the case was held on January 9, 2018. The case came on a writ of certiorari to the Supreme Court of Virginia.

HIGHLIGHTS
  • The case: Ryan Collins was found guilty of receiving stolen property after a motorcycle in his possession was found to have been stolen. A police officer proved it was stolen by tracking its vehicle identification number (VIN). The officer obtained the VIN by entering private property without permission or a warrant, pulling off a tarp that had covered the motorcycle, and recording the VIN. Collins argued that the officer's warrantless search was unconstitutional and moved to suppress all evidence obtained as a result of the search. The trial court denied his motion. The Supreme Court of Virginia affirmed, concluding that the automobile exception to the Fourth Amendment's prohibition against warrantless searches applied and that the search was therefore lawful.
  • The issue: "Whether the Fourth Amendment's automobile exception permits a police officer, uninvited and without a warrant, to enter private property, approach a home, and search a vehicle parked a few feet from the house."[1]
  • The outcome: On a vote of 8 - 1, the U.S. Supreme Court reversed the Virginia Supreme Court. The U.S. Supreme Court ruled that the automobile exception did not permit a warrantless search of a vehicle parked in the driveway of a home.[2]


    • You can review the Virginia Supreme Court's opinion here.[3]

    Background

    Legal question

    This was a case about the application of the automobile exception to the Fourth Amendment prohibition against warrantless searches.

    The Fourth Amendment to the United States Constitution states:

    “ The right of the people to be secure in their persons, houses, papers, and effects, against unreasonable searches and seizures, shall not be violated, and no Warrants shall issue, but upon probable cause, supported by Oath or affirmation, and particularly describing the place to be searched, and the persons or things to be seized.[4] ”

    The automobile exception to the Fourth Amendment prohibition allows officers to search a vehicle without a warrant in specific circumstances. "In cases where there was probable cause to search a vehicle," the United States Supreme Court previously ruled, "a search is not unreasonable if based on facts that would justify the issuance of a warrant, even though a warrant has not been actually obtained." Put another way, “If a car is readily mobile and probable cause exists to believe it contains contraband, the Fourth Amendment...permits police to search the vehicle without more.”[3] In this case, the supreme court considered whether the automobile exception permits an officer to enter private property without permission or a warrant and search a motorcycle that is standing a few feet from the house on the property.

    Case background

    In summer 2013, two separate police officers of the Albemarle County Police Force observed the rider of a black and orange motorcycle with an extended frame commit traffic infractions. In each case, the officer attempted to pull the vehicle over, but the driver sped away and the officers were unable to follow. The second officer was able to record the motorcycle's license number and description. It was an "orange and black Suzuki with chrome accents and a 'stretched out' rear wheel, indicating that it had been modified for drag racing." The officers concluded that the same motorcycle was involved in both traffic incidents. The license plate search revealed that the vehicle's tags had not been active for several years. After some investigation, the officer determined that Collins was the current owner of the black and orange motorcycle.[3]

    Weeks later, the officers overheard Collins' name on the police radio and learned that Collins was being questioned at the DMV about a different matter. They found pictures on Collins' Facebook page of the motorcycle outside a house. The officers went to the DMV and questioned Collins about the motorcycle. Collins denied any knowledge of the motorcycle. Collins then left.

    One of the officers learned the location of the house in the photographs from Collins' Facebook page. He drove to the street where the house was located to conduct surveillance. After he identified the house from the picture, he noticed what appeared to be a motorcycle covered by a white tarp sitting in the house's driveway. The officer testified that part of the motorcycle's wheel was visible. He testified that what he could see of the motorcycle--specifically, its size and some of its chrome accents--matched his memory of the black and orange motorcycle.

    The officer then walked onto the property, removed the white tarp, and recorded the VIN. He concluded it was the black and orange motorcycle he had chased earlier that year. He recovered the motorcycle and left the property.

    Collins arrived at the house about a half an hour later. The officer knocked on the door, and when Collins answered, the officer questioned him about the motorcycle. Collins eventually admitted that he knew the motorcycle did not have a title. He was later arrested for receipt of stolen property.[3]

    At trial, Collins argued that the officer's search of the motorcycle was unconstitutional because he did not have a warrant or consent to enter the property and conduct the search. Collins argued that the officer had trespassed on private property and conducted the search without probable cause or exigent circumstances that would have legitimized the search. Collins moved to suppress the evidence gathered as a result of the officer's search. That evidence included the VIN, which allowed police to confirm that the motorcycle had been stolen. In response, the state argued that the search was lawful under the automobile exception. The state argued that where the automobile exception applies, "Probable cause alone is enough to justify a search and a warrant is unnecessary." Collins countered that the automobile exception allowed the "search of the automobile[,] not a search for an automobile," and that it was intended for use by officers who stop vehicles on the street.[3]

    The trial court judge agreed with the state and denied Collins' motion to suppress. Collins was later convicted at trial.[3] Following his conviction, Collins appealed the trial court's ruling on the constitutionality of the search. The Virginia Court of Appeals affirmed, though on grounds other than the automobile exception. Collins appealed to the Supreme Court of Virginia[3]

    Virginia Supreme Court opinion

    The Virginia Supreme Court ruled that the officers' search was constitutional under the automobile exception. Because the court concluded that the automobile exception applied, it also considered whether the officer had probable cause for the search. The court stated:

    “ Warrantless searches, of course, are per se unreasonable, subject to a few well-defined exceptions...The Supreme Court has articulated a simple, bright-line test for the automobile exception: '[i]f a car is readily

    mobile and probable cause exists to believe it contains contraband, the Fourth Amendment . . . permits police to search the vehicle without more.' Applying that test to this case, we hold that Officer Rhodes’ warrantless search of the motorcycle was justified under the automobile exception to the warrant requirement of the Fourth Amendment. [3][5][4]

    		”

    One Justice, Justice Bill Mims, dissented from the court's ruling. Mims would have ruled that the automobile exception did not apply to the officer's search. Mims wrote, "The automobile exception permits a warrantless search of a vehicle, not for a vehicle."[6] Noting that the exception refers to a vehicle that an officer believes contains contraband, he continued, "The motorcycle did not contain contraband, it was contraband; Officer Rhodes did not search the motorcycle, he searched the tarp."[3]

    Petitioner's challenge

    Ryan Collins, the petitioner, challenged the holding of the Supreme Court of Virginia. Collins argued that the Supreme Court of Virginia erred in concluding that the automobile exception permitted the officer to enter his property and search the motorcycle.

    Certiorari granted

    On February 21, 2017, Ryan Collins, the petitioner, initiated proceedings in the Supreme Court of the United States in filing a petition for a writ of certiorari to the Supreme Court of Virginia. The U.S. Supreme Court granted Collins' request for certiorari on September 28, 2017. Argument in the case was held on January 9, 2018.[1]

    Question presented

    Question presented:

    "Whether the Fourth Amendment's automobile exception permits a police officer, uninvited and without a warrant, to enter private property, approach a home, and search a vehicle parked a few feet from the house."[1]

    Audio

    • Audio of oral argument:[7]



    Transcript

    • Transcript of oral argument:[8]

    Outcome

    Decision

    On a vote of 8 - 1, the U.S. Supreme Court reversed the Virginia Supreme Court's ruling. The U.S. Supreme Court ruled that the automobile exception did not permit a warrantless search of a vehicle parked in the driveway of a home.[2]

    Majority opinion

    Justice Sonia Sotomayor authored the opinion for the court majority, joined by all the justices except Justice Samuel Alito. Sotomayor ruled, “We conclude that the automobile exception does not permit an officer without a warrant to enter a home or its curtilage in order to search a vehicle therein.”[2]

    Sotomayor first emphasized that “the Fourth Amendment’s protection of curtilage has long been black letter law.” Curtilage, she explained, is “the area ‘immediately surrounding and associated with the home’,” and it is considered “to be part of the home itself for Fourth Amendment purposes.” Therefore, she concluded, “Officer Rhodes not only invaded Collins’ Fourth Amendment interest in the item searched, i.e., the motorcycle, but also invaded Collins’ Fourth Amendment interest in the curtilage of his home” when the officer walked up the driveway and uncovered the motorcycle.[2]

    Because the search at issue constituted a search of the home and not just the vehicle, she continued, the automobile exception did not apply. “Nothing in our case law,” she wrote, “suggests that the automobile exception gives an officer the right to enter a home or its curtilage to access a vehicle without a warrant.”[2]

    “ Just as an officer must have a lawful right of access to any contraband he discovers in plain view in order to seize it without a warrant, and just as an officer must have a lawful right of access in order to arrest a person in his home, so, too, an officer must have a lawful right of access to a vehicle in order to search it pursuant to the automobile exception. The automobile exception does not afford the necessary lawful right of access to search a vehicle parked within a home or its curtilage because it does not justify an intrusion on a person’s separate and substantial Fourth Amendment interest in his home and curtilage.[2][4] ”


    While the court reversed the Supreme Court of Virginia’s decision regarding the automobile exception, it did not foreclose the possibility that the search might be constitutional under another exception. Sotomayor concluded, “We leave for resolution on remand whether Officer Rhodes’ warrantless intrusion on the curtilage of Collins’ house may have been reasonable on a different basis, such as the exigent circumstances exception to the warrant requirement.”[2]

    Justice Thomas’ concurrence

    Justice Clarence Thomas joined the majority’s opinion in full and also wrote separately. Thomas wrote to suggest that the court should in a future case reconsider the application of the exclusionary rule, which requires courts to exclude evidence obtained through a search when the search is declared unconstitutional:

    “ I join the Court’s opinion because it correctly resolves the Fourth Amendment question in this case. Notably, the only reason that Collins asked us to review this question is because, if he can prove a violation of the Fourth Amendment, our precedents require the Virginia courts to apply the exclusionary rule and potentially suppress the incriminating evidence against him. I write separately because I have serious doubts about this Court’s authority to impose that rule on the States . . . We have not yet revisited that question in light of our modern precedents, which reject ‘’Mapp’’’s essential premise that the exclusionary rule is required by the Constitution. We should do so.[2][4] ”


    Dissent by Justice Alito

    Justice Samuel Alito dissented from the court’s opinion. Alito felt that “what the police did in this case was entirely reasonable.” He would have ruled that the officer’s search of the motorcycle was reasonable and, therefore, did not violate the Fourth Amendment. Alito argued that the court should have decided whether the rationales that underlie the automobile exception--namely, the fact that automobiles can be moved quickly and that privacy interests in automobiles are not as significant as privacy interests in a home--apply here. He believed they did.

    “ In considering that question, we should ask whether the reasons for the ‘automobile exception’ are any less valid in this new situation. Is the vehicle parked in the driveway any less mobile? Are any greater privacy interests at stake? If the answer to those questions is ‘no,’ then the automobile exception should apply. And here, the answer to each question is emphatically ‘no.’ The tarp-covered motorcycle parked in the driveway could have been uncovered and ridden away in a matter of seconds. And Officer Rhodes’s brief walk up the driveway impaired no real privacy interests . . . After all, the ultimate inquiry under the Fourth Amendment is whether a search is reasonable, and that inquiry often turns on the degree of the intrusion on privacy.[2][4] ”


    Text of the opinion

    See also

    Footnotes

    1. ↑ 1.0 1.1 1.2 Supreme Court of the United States, Collins v. Virginia Question Presented, September 28, 2017
    2. ↑ 2.0 2.1 2.2 2.3 2.4 2.5 2.6 2.7 2.8 United States Supreme Court, "Collins v. Virginia Opinion," May 29, 2018
    3. ↑ 3.0 3.1 3.2 3.3 3.4 3.5 3.6 3.7 3.8 United States Supreme Court, Collins v. Virginia Virginia Supreme Court opinion, September 15, 2016
    4. ↑ 4.0 4.1 4.2 4.3 4.4 Note: This text is quoted verbatim from the original source. Any inconsistencies are attributable to the original source.
    5. ↑ Internal citation omitted.
    6. ↑ Emphasis in original.
    7. ↑ Supreme Court of the United States, Byrd v. United States, argued January 9, 2018
    8. ↑ Supreme Court of the United States, Byrd v. United States, argued January 9, 2018
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