Collins v. Commonwealth

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The Supreme Court affirmed the decision of the court of appeals affirming Defendant's conviction after the trial court had denied Defendant's motion to suppress, holding that the exclusionary rule did not apply under the facts of this case. Defendant was convicted of stolen property. At issue on appeal was whether the trial court should have excluded evidence obtained by police officers during a warrantless search of a motorcycle parked on a private residential driveway. The case made its way to the United States Supreme Court, which held that the automobile exception to the Fourth Amendment does not permit a police officer to enter the curtilage of a home without a warrant in order to search a vehicle parked on that curtilage. The Supreme Court left for resolution on remand whether the warrantless intrusion on Defendant's house may have been reasonable on a different basis. On remand, the Supreme Court affirmed the trial court's denial of Defendant's motion to suppress, holding that the good faith exception to the exclusionary rule applied because, at the time of the search, a reasonably well-trained police officer would not have known that the automobile exception did not permit him to search a motorcycle located a few feet across the curtilage boundary of a private driveway. View "Collins v. Commonwealth" on Justia Law