United States v. Dunn case brief

United States v. Dunn case brief summary
480 U.S. 294 (1987)

CASE SYNOPSIS

The United States Court of Appeals for the Fifth Circuit reversed defendant's conviction for drug-related offenses on the grounds that certain evidence obtained as a result of drug enforcement agents' entry onto an area surrounding defendant's barn should have been suppressed. The government appealed.

CASE FACTS
Drug enforcement agents began investigating defendant after he purchased large quantities of chemicals used to manufacture illegal drugs. The agents watched defendant place the chemicals in a barn on his ranch and observed a laboratory. Agents then made a warrantless entry on the property to confirm their suspicions. After obtaining a warrant, the agents arrested defendant. Defendant was convicted of drug-related offenses.

PROCEDURAL HISTORY

• The appellate court reversed defendant's conviction finding that the evidence should have been suppressed because it was seized pursuant to the unlawful warrantless entry. 
• The appellate court also found that the barn was within the protective ambit of the Fourth Amendment because it was within the curtilage of the residence. 

DISCUSSION

• On appeal, the court held that the barn lay outside the curtilage of the ranch house. 
• The barn was 50 yards from the fence surrounding the house and 60 yards from the house itself. 
• The barn did not lie within the area surrounding the house that was enclosed by a fence. 
• Agents also knew that the barn was not being used for intimate activities of the home.

CONCLUSION

The court reversed the decision because the area surrounding the barn did not lie within the curtilage of defendant's ranch house. The Fourth Amendment protections afforded defendant's house could not be expanded to include the area surrounding the barn.

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