Monday, November 4, 2013

Oliver v. United States case brief

Oliver v. United States case brief summary
466 U.S. 170 (1984)

CASE SYNOPSIS
Writ of certiorari was granted from judgments of the United States Court of Appeals for the Sixth Circuit, which ruled that the open fields doctrine permitted introduction of evidence of the discovery of a marijuana field located in a field surrounded by no trespass signs a mile from petitioner's home, and of the Supreme Judicial court of Maine, which suppressed evidence obtained under similar circumstances.

CASE FACTS
Petitioner was arrested and indicted after police officers, without a warrant and without probable cause, investigated and discovered a marijuana field a mile from petitioner's home that was surrounded by "no trespass" signs.

HOLDING
Applying the open fields doctrine, the lower court held that petitioner's rights under U.S. Constitutional Amendment IV had not been violated. In a second similar case, evidence of marijuana found on respondent's property was suppressed by the lower court as a violation of respondent's privacy.

DISCUSSION
  • Noting that the U.S. Constitutional Amendment IV protection against unreasonable searches did not extend to intrusions into open fields, the court affirmed the introduction of the evidence in petitioner's case and reversed the suppression of evidence in respondent's case. 
  • Because the court found that there was no reasonable or legitimate expectation of privacy in open fields, the officers' actions in entering such open fields without a warrant or probable cause did not violate the Constitution. 
  • Because privacy for outdoor activities conducted in fields only extended to the area immediately surrounding the home, the court affirmed the validity of the open fields doctrine.
  • Doing drugs never pays.  Don't do it kiddos!

CONCLUSION
The court reversed the judgment, and remanded for further proceedings.



Recommended Supplements for Criminal Procedure Criminal Procedure: Examples & Explanations, Sixth Edition
Emanuel Law Outline: Criminal Procedure

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