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California v. Carney

It Is A Car

The state of California appealed the decision to the U.S. Supreme Court, which reversed the decision by a vote of 6-3. Chief Justice Burger, writing for the majority, noted at the outset the long-standing rule allowing warrantless searches of motorized vehicles. Citing U.S. Supreme Court precedent, Carroll v. United States (1925) Burger stated that a vehicle's "capacity to be `quickly moved'" was the reason for allowing warrantless searches of automobiles. Burger went on to observe that the mobility of the automobile was only the initial justification for the rule. Since the Carroll case, the Court also had decided in South Dakota v. Opperman (1976) that another reason for the rule was because persons have a lesser expectation of privacy in motorized vehicles. This result in Opperman, Burger explained, stemmed from long-standing, widely known government regulations of the automobile, "which necessarily lead to reduced expectations of privacy."

Applying these rules to Carney's case, the majority found that Carney's motor home was "readily mobile," that the motor home had a valid license to operate on public roads, and that it was subject to government regulations. Furthermore, Carney's motor home "was so situated [in a parking lot] that an observer would conclude that it was being used not as a residence, but as a vehicle." These factors contributed to the Court's conclusion that the privacy afforded to a mobile home under the Fourth Amendment did not prohibit warrantless searches. Allowing police to conduct warrantless searches on mobile homes that are being used for transportation "ensure[s] that law enforcement officials are not unnecessarily hamstrung in their efforts to detect and prosecute criminal activity, and that the legitimate privacy interests of the public are protected." By determining first whether a mobile home is in fact mobile and whether it is being used for transportation, law enforcement personnel may fulfill the "essential purposes" of the automobile exception, "while assuring that the exception will acknowledge legitimate privacy interests."

As a final matter, the Court addressed the issue of whether the particular search conducted in Carney's case was reasonable. Citing the "fresh, direct, uncontradicted evidence" that Carney was dispensing marijuana from his motor home, Burger declared that the agents "had abundant probable cause to enter and search the vehicle . . . notwithstanding its possible use as a dwelling place."

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Law Library - American Law and Legal InformationNotable Trials and Court Cases - 1981 to 1988California v. Carney - Is It A Car Or A Home?, It Is A Car, It Is A Home