State v. Chute

Summary

The Minnesota Supreme Court held that a police officer conducted an unlawful Fourth Amendment search by entering the curtilage of the defendant’s home and inspecting a camper without a warrant. Although the driveway was impliedly open to the public for visitors seeking access to the home or garage, the officer exceeded that implied license by proceeding directly to and examining the camper. The court affirmed the court of appeals’ decision, including its conclusion that the unlawful search tainted the defendant’s subsequent consent to a search of his home.

Holdings

1. The camper was parked within the curtilage of Chute's home and was therefore protected by the Fourth Amendment.
2. The officer's warrantless entry onto the curtilage and examination of the camper exceeded the spatial, purposive, and temporal limits of any implied license to approach the home and constituted an unreasonable Fourth Amendment search.
3. The plain-view doctrine did not authorize the officer's examination of the camper because that doctrine supplies an exception for warrantless seizures, not for an otherwise unlawful search, and the officer was not lawfully in a position to inspect the camper.

Questions Presented

1. Whether the camper was located within the curtilage of Chute's home and therefore protected by the Fourth Amendment.
2. Whether the officer's warrantless entry onto the property and examination of the camper fell within the scope of an implied license to approach the home or otherwise constituted a Fourth Amendment search.
3. Whether the plain-view doctrine authorized the officer's conduct.

Disposition

affirmed