United States Supreme Court Holds Warrantless Search of Motorcycle on Curtilage Illegal

In this case, police officers were in search for an elusive, speeding motorcycle. They developed evidence that the motorcycle may be stolen, and that it might be located on the defendant’s girlfriend’s property. An officer went to that house, saw a motorcycle covered by a tarp on the driveway, entered the property and lifted the tarp to access the vehicle’s license plate and identification numbers. The officer then confirmed that the motorcycle was stolen.

The trial court denied a motion to suppress, and on appeal, the Virginia Court of Appeals and the State Supreme Court both affirmed. The State Supreme Court found specifically that the automobile exception to the requirement of a warrant applied here.

The Supreme Court, in an 8-1 decision, reversed. In an opinion by Justice Sotomayor, the Court found that the automobile exception does not extend to parked vehicles on private property where the defendant has a privacy interest. In this case, they had no trouble concluding that the officer could not go onto the private driveway to recover the license plate and VIN numbers.

The case is Collins v. Virginia, 16-1027

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