California v. Carney:   
United States Supreme Court, 1985. 

Statement of the Case:

      Carney, marijuana for sex seller, contends that law enforcement agents violated the 4^th Amendment when they conducted a warrantless search of a motor home, located in a public place, based on probable cause.

Procedure:

      Lower courts suppressed the evidence.

Facts:

        DEA agent stopped a kid leaving Carney’s mobile home after some suspicious activity, and the kid told him he traded sex for weed.  The officer made the kid go back, and when Carney came to the door, arrested him.

      Carney did not consent to a search, but the officers did anyway, without a warrant, and found drugs, scales, etc.

Issue:

      Whether law enforcement agents violated the 4^th Amendment when they conducted a warrantless search of a motor home, located in a public place, based on probable cause.

Procedural Result:

      Judgment reversed for State.

Holding:

      Law enforcement agents DID NOT violate the 4^th Amendment when they conducted a warrantless search of a motor home, located in a public place, based on probable cause, since a motor home is generally a vehicle.

Reasoning:

• Mobility of automobiles creates circumstances of such exigency that, as a practical necessity, rigorous enforcement of the warrant requirement is impossible.
• Also, the expectation of privacy in a motor-vehicle is lower than in a home.
• While motor home possesses some of the attributes of a home, it is used more like a vehicle.
• Not applying the exception here makes a motor home the ideal place to deal drugs…

Dissent:

• Priority should be given to the rule, not the exception, since a motor home is in-between a home and a vehicle.

Additional Points: 

• Pennsylvania v. Labron; Pennsylvania v. Kilgore:  Officers searched cars without exigent circumstances, and the US Supreme Court overruled PA’s ruling that the lack of exigent circumstances invalidated the searches. 
  
• Florida v. White:  Officers searched ?’s car months after seeing it used to deliver cocaine.  US Supreme Court overruled Florida’s ruling that the lack of exigent circumstances invalidated the searches.