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Student Project: Searches and Seizures of Automobiles: Developing Supreme Court Cases

This research guide facilitates the analysis of the Fourth Amendment for searches and seizures of automobiles under federal and New York State law.


This section of the guide focuses on three significant Supreme Court cases which are currently pending. Collins, Byrd, and Carpenter involve the reasonable expectation of privacy in automobiles. In Collins, the question before the Court is the scope of the search within the automobile exception. In Byrd, the question before the Court is does a person not listed as an authorized driver have standing. In Carpenter, the question before the Court is whether accessing cell site location information a search which requires a warrant. How the Court comes out on these cases may reshape the standard analysis for the reasonable expectation of privacy in automobiles. 

Collins v. Virginia

Collins v. Virginia 

Police officers were not able to pull over a motorcyclist who speeded away. Officers saw a motorcycle parked in a driveway where Ryan Collins usually spent time. Officers entered the driveway and lifted the tarp which was covering the motorcycle. Officers then ran the vehicle’s license plate and vehicle identification number through the system which indicated that the motorcycle had been stolen. The question before the Court is the search within the scope of the automobile exception.

Carpenter v. United States

Carpenter v. United States 


Police arrested four men for a series of armed robberies. One of the defendants confessed to the crimes and informed the FBI of his phone number and the other defendants' phone numbers. FBI obtained transactional records which included the date, time, and the location where the call took place based on their connections to the cell towers. This data is from wireless carriers which generate hundreds of times per day and include the GPS coordinate every time the phone tried to connect to it. The FBI linked the information from the transactional records to place the suspects in the robberies' locations. The transactional records were not limited to the days and times of the known robberies. Timothy Carpenter was charged with aiding and abetting robbery, among other offenses. Carpenter argued that the FBI needed a warrant based on probable cause to obtain the records. The question before the Court is whether the Fourth Amendment’s privacy protection against warrantless search and seizure extends to data records. Automobiles, like cell phones, have in recent years become increasingly software driven. Automobiles are easily linked to smartphones, offer emergency roadside assistance, and provide wireless internet connection; all these features come from the same wireless carriers and cell towers. 

Byrd v. United States

Byrd v. United States 

Byrd was driving a rental automobile on the left side of the highway in Pennsylvania. He was pulled over for violating a state law which required drivers to drive on the left lane only when passing. During the stop, officers noticed that the rental agreement did not list Byrd as an authorized driver. After checking his identification, officers realized that he was using an alias and had an outstanding warrant in New Jersey. Officers searched the automobile and found heroin and body armor in the trunk. Officers allege that Byrd gave consent to the search, but Byrd disputes that. The question before the court is whether Byrd had a reasonable expectation of privacy in the rental automobile.

Digest Topic and Key Numbers**

349 Searches and Seizures

349k59 Vehicles, vessels, and aircraft in general

349k60 Motor Vehicles

349k62 Probable or reasonable cause

 ** Requires subscription to Westlaw