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Oliver v. U.S. (1984)
Petitioner: Mr. Oliver; Oliver was convicted for growing marihuana in his fields. Two officers entered Oliver's field without a search warrant and they used the evidence obtained in the field to convict the defendant.
Respondent: U.S. Government
Issue: Katz Test 1. Did the petitioner have subjective expectation of privacy in his fields? 2. Is the society ready to accept this expectation as reasonable?
Holding: 1. Yes, 2. No
Key Facts: Oliver had a wooden fence around his fields and he had placed 'No Trespassing' signs on the fence. In Hester v. United States, the Supreme Court allowed police officers to enter open fields without a warrant under the 'open field' exception.
Legal Reasoning: Even though the defendant had placed fence around the field, it was still visible from the top and the police officers could have seen the marihuana from an airplane or a helicopter. So the defendant's expectation of privacy in his fields is not objectively reasonable. In order for a place to be protected under the Fourth Amendment, the person must not only show subjective expectation of privacy in the place in question, but he must also prove that the expectation of privacy is reasonable from the standards of the society. The petitioner in the current case fails to fulfill the second requirement of the Katz Test so his conviction stayed.