California v. Carney
Following is the case brief for California v. Carney, 471 U.S. 386 (1985)
Case Summary of California v. Carney:
- Respondent provided marijuana to a youth in exchange for sexual favors in respondent’s motor home. Following the transaction, federal agents entered the motor home without consent or a warrant.
- Respondent unsuccessfully moved to suppress the marijuana evidence, and then pleaded no contest to marijuana charges.
- On appeal, the California Supreme Court held that the search of the motor home was a violation of the Fourth Amendment.
- The U.S. Supreme Court reversed that decision. The Court held that the automobile exception to the Fourth Amendment’s warrant requirement applied to respondent’s motor home.
California v. Carney Case Brief
Statement of the Facts:
Following a tip that respondent Carney was using his motor home to provide marijuana in exchange for sexual favors, a federal agent observed respondent approach a youth who followed respondent into the motor home. The motor home was parking in a lot in San Diego. After the youth left the motor home, agents spoke to him. The youth indicated that he allowed respondent sexual contact in order to get marijuana.
The agents then asked the youth to knock on the motor home door, which he did. When respondent answered, the agents entered the motor home without a warrant or respondent’s consent. The agents observed marijuana and paraphernalia in the motor home. They charged respondent with possession of marijuana for sale.
- Respondent pleaded no contest to the charge after the court denied his motion to suppress the evidence found in his motor home. The court sentenced him to three years probation.
- The California Court of Appeal affirmed the trial court’s denial of respondent’s motion.
- The California Supreme Court, however, reversed. It held that the motor home is more like a dwelling, so the automobile exception did not apply to the warrantless search in this case.
- The U.S. Supreme Court granted certiorari.
Issue and Holding:
Does the automobile exception to the Fourth Amendment’s warrant requirement apply to the warrantless search of a motor home in a public place? Yes.
The judgment of the California Supreme Court is reversed and remanded.
Rule of Law or Legal Principle Applied:
A motor home in a public place is more like a vehicle such that the automobile exception to the warrant requirement of the Fourth Amendment applies.
The automobile exception to the Fourth Amendment’s warrant requirement, which recognizes a lesser expectation of privacy in a vehicle, applies here. The motor home in this case was readily mobile, and an objective observer would conclude that it was being used in this case as a vehicle, not a residence.
In addition, the search was not unreasonable. Based on observation and the statements of the youth, the agents had ample probable cause to believe that respondent was distributing marijuana from the motor home.
Dissenting Opinion (Stevens):
The hybrid nature of the motor home — functioning as both a home and a vehicle — puts it between constitutional protections necessary for a home and the warrant exception allowed for a vehicle. The Court’s opinion is wrong in three ways: (i) it has prematurely ventured into lessening protection for other types of vehicles that also can be dwellings; (ii) it favored an exception over the general rule of requiring a warrant under the Fourth Amendment; and (iii) it ignored limits on the automobile exception discussed in prior cases.
California v. Carney made a choice between treating a motor home as a vehicle rather than a home, even though it has aspects of both. It appears that choice was informed to a large degree by the specific facts of the case, whereby the motor home in question was in a public parking lot (not a trailer park) and was drivable. It would be interesting to inquire whether the Court would have come to the same conclusion if the motor home was in a trailer park, and it was being used in a fashion similar to a trailer home.