United States v. Dunn
Encyclopedia
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.
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 (45.7 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. 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:
Case citation
Case citation is the system used in many countries to identify the decisions in past court cases, either in special series of books called reporters or law reports, or in a 'neutral' form which will identify a decision wherever it was reported...
(1987), is a U.S. Supreme Court
Supreme Court of the United States
The Supreme Court of the United States is the highest court in the United States. It has ultimate appellate jurisdiction over all state and federal courts, and original jurisdiction over a small range of cases...
decision relating to the open fields doctrine
Open fields doctrine
The open fields doctrine is a U.S. legal doctrine created judicially for purposes of evaluating claims of an unreasonable search by the government in violation of the Fourth Amendment of the U.S...
limiting the Fourth Amendment
Fourth Amendment to the United States Constitution
The Fourth Amendment to the United States Constitution is the part of the Bill of Rights which guards against unreasonable searches and seizures, along with requiring any warrant to be judicially sanctioned and supported by probable cause...
of the U.S. Constitution.
Investigation
The Drug Enforcement AgentsDrug Enforcement Administration
The Drug Enforcement Administration is a federal law enforcement agency under the United States Department of Justice, tasked with combating drug smuggling and use within the United States...
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 (45.7 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
United States district court
The United States district courts are the general trial courts of the United States federal court system. Both civil and criminal cases are filed in the district court, which is a court of law, equity, and admiralty. There is a United States bankruptcy court associated with each United States...
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
Curtilage
The curtilage is an important legal term to define the land immediately surrounding a house or dwelling, including any closely associated buildings and structures, but excluding any associated 'open fields beyond'. It defines the boundary within which a home owner can have a reasonable expectation...
and therefore within the Fourth Amendment's protective ambit. 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:
See also
- List of United States Supreme Court cases, volume 480
- List of United States Supreme Court cases
- Lists of United States Supreme Court cases by volume
- List of United States Supreme Court cases by the Rehnquist Court