Tuesday, November 5, 2013

California v. Ciraolo case brief

California v. Ciraolo case brief summary
476 U.S. 207 (1986)

CASE SYNOPSIS
Plaintiff, the State of California, petitioned for writ of certiorari from decision of the Court of Appeals of California, First Appellate District, which reversed trial court's denial of defendant's motion to suppress evidence of search on ground that the warrantless aerial observation of defendant's yard violated U.S. Constitutional Amendment IV.

CASE FACTS
The trial court denied defendant's motion to suppress evidence of a search, and defendant pled guilty to a charge of cultivation of marijuana. The appellate court reversed on the ground that the warrantless aerial observation which led to the issuance of a search warrant violated U.S. Constitutional Amendment IV.

DISCUSSION
  • On certiorari, the Court held that, although defendant's yard was within the curtilage of his home, this did not bar police observation. 
  • The Court stated that Fourth Amendment protection of the home had never been extended to require law enforcement officers to shield their eyes when passing by a home on public thoroughfares. 
  • Nor did the mere fact that defendant had erected a 10-foot fence around his yard preclude an officer's observations from a public vantage point where he had a right to be and which rendered activities clearly visible. 
  • Defendant's expectation that his yard was protected from observation was unreasonable and not an expectation that society was prepared to honor.

CONCLUSION

The court reversed the appellate court's judgment and found that defendant's motion to suppress was properly denied.

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

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