Commonwealth v. OusleyAnnotate this Case
Without a search warrant, police walked onto Appellee's property and into an area near his home late at night to search trash in closed trash containers that had not been put out on the street for trash collection. The containers ended up containing evidence of drug trafficking. The trial court denied suppression of the evidence, concluding that Defendant had no reasonable expectation of privacy in the trash cans or their contents. Defendant entered a conditional guilty plea to all the charges, reserving his right to appeal the suppression question. The court of appeals reversed, holding that Defendant had a constitutionally recognized expectation of privacy in his trash at the time of the searches that required suppression of the evidence. The Supreme Court affirmed, holding that because the police retrieved Defendant's trash from the curtilage of his home without a search warrant, the search violated Defendant's Fourth Amendment rights, and Defendant was entitled to have the evidence obtained suppressed.