Florida v. Riley

Summary

The Supreme Court held that police observation of marijuana plants in a partially covered greenhouse from a helicopter flying 400 feet above the property was not a search under the Fourth Amendment. The Court reversed the Florida Supreme Court, reasoning that the observation occurred from a lawful aerial vantage point and did not violate a reasonable expectation of privacy.

Holdings

1. Under the circumstances presented, naked-eye observation of the greenhouse from a helicopter flying lawfully at 400 feet did not constitute a search under the Fourth Amendment because Riley had no reasonable expectation that the partially exposed contents of the greenhouse would remain free from observation from that vantage point.
2. The United States Supreme Court had jurisdiction because the Florida Supreme Court's decision was not clearly and expressly based on an adequate and independent state-law ground.

Questions Presented

1. Whether warrantless naked-eye observation from a helicopter flying 400 feet above a partially covered greenhouse in the curtilage of a home constitutes a search under the Fourth Amendment.
2. Whether the Florida Supreme Court's judgment rested on an adequate and independent state constitutional ground depriving the United States Supreme Court of jurisdiction.

Disposition

reversed