Collins v. Virginia

Police officers, investigating a motorcycle that had evaded them, traced it to a residential driveway partially covered by a tarp. Without a search warrant, an officer walked onto the curtilage of the home, lifted the tarp, and ran a check on the vehicle identification number, confirming it was stolen. Ryan Collins was later charged with receiving stolen property. He moved to suppress the evidence, arguing the warrantless search violated the Fourth Amendment. The Virginia Supreme Court upheld the search under the automobile exception. Collins appealed to the U.S. Supreme Court, which granted certiorari to determine whether the automobile exception permits a warrantless search of a vehicle parked within the home's curtilage.

In an 8-1 decision authored by Justice Sonia Sotomayor, the U.S. Supreme Court reversed the Virginia Supreme Court. It held that the automobile exception does not justify a warrantless invasion of the home's curtilage to search a vehicle, and remanded the case for further proceedings.

Whether the Fourth Amendment's automobile exception permits a police officer, without a warrant, to enter the curtilage of a home to search a vehicle parked there.

The ruling reinforced the Fourth Amendment's strong protection of the curtilage area immediately surrounding a home, setting a clear boundary that the automobile exception to the warrant requirement does not allow police to trespass onto private driveways to conduct a search without a warrant. It clarified the intersection of privacy rights and vehicle searches, influencing law enforcement procedures nationwide.