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United States v. Dunn

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Full case name
  
United States v. Dunn

Concurrence
  
Scalia

Citations
  
480 U.S. 294 (more)

Date decided
  
1987

Majority
  
White, joined by Rehnquist, Blackmun, Powell, Stevens, O'Connor

Dissent
  
Brennan, joined by Marshall

Similar
  
California v Greenwood, Arizona v Hicks, Muehler v Mena, Maryland v Pringle, California v Acevedo

United States v. Dunn, 480 U.S. 294 (1987), is a U.S. Supreme Court decision relating to the open fields doctrine limiting the Fourth Amendment of the U.S. Constitution.

Contents

Investigation

The Drug Enforcement Agents began investigating the defendant when he purchased large quantities of chemicals used in the production of illegal drugs. The officers then witnessed the defendant placing these chemicals in a barn on his private ranch. The ranch was completely encircled by a perimeter fence, and contained several interior barbed wire fences, including one around the house approximately 50 yards (46 m) from the barn, and a wooden fence enclosing the front of the barn, which had an open overhang and locked, waist-high gates. Without a warrant, officers crossed the perimeter fence, several of the barbed wire fences, and the wooden fence in front of the barn. They were led there by the smell of chemicals, and, while there, could hear a motor running inside. They did not enter the barn but stopped at the locked gate and shined a flashlight inside, observing what they took to be a drug laboratory. They then left the ranch, but entered it twice the next day to confirm the laboratory's presence.

They obtained a search warrant and executed it. The equipment was feeding off the mains. The DEA arrested the respondent, seizing chemicals and equipment, as well as bags of amphetamines they discovered in the house. After the District Court denied the defendant’s motion to suppress all evidence seized pursuant to the warrant and the defendant was convicted of conspiracy to manufacture controlled substances and related offenses. However, the Court of Appeals reversed that decision, holding that the barn was within the residence's curtilage and therefore within the Fourth Amendment's protective ambit.

Decision

In an opinion for the majority by Justice White, the Supreme Court overturned the appeals court’s decision, finding that the barn was outside the curtilage and so all evidence obtained by the officers while standing outside the barn and looking in was admissible. Looking at whether the barn was inside the curtilage or rather in an open field, the Court stated:

References

United States v. Dunn Wikipedia