State v. ChuteAnnotate this Case
The warrantless search of Defendant’s property violated Defendant’s Fourth Amendment rights in this case.
Here, an officer entered Defendant’s property, examined a stolen camper trailer and then, after obtaining Defendant’s consent, searched Defendant’s home. Defendant filed a motion to suppress, arguing that the officer’s examination of the camper was unconstitutional and tainted his subsequent consent to the search of his home. The district court denied the motion to suppress, concluding that because the camper was on a driveway that was impliedly open to the public, the officer’s entry onto Defendant’s property was lawful and that the officer had authority to seize the camper under the plain-view doctrine. The court of appeals reversed. The Supreme Court affirmed, holding (1) the camper was located on property that was afforded the constitutional protections of the home; and (2) the officer’s conduct was beyond the objectively reasonable scope of any implied license to enter Defendant’s property, and therefore, the warrantless search violated Defendant’s Fourth Amendment rights.