Anthony is currently a County Civil Prosecutor and has his Juris Doctorate. He has been a guest lecturer at several local universities.
Police Officers in Laguna Beach were conducting a drug trafficking investigation. The target of the investigation was Billy Greenwood. During this investigation, the Laguna Beach Police Department asked Mr. Greenwood's trash collector to place Greenwood's garbage separately from the other trash they normally picked up. When investigating Greenwood's garbage, the police officers found evidence of drug use. They then used this evidence to obtain a search warrant, a legal document permitting the searching of property by police or the government, to search Mr. Greenwood's home. Once inside his home, they then found evidence of drug use and trafficking.
Using this evidence, the police arrested Mr. Greenwood. Greenwood then posted bail, or a certain amount to be released from incarceration to ensure court appearances, and was released from jail during the pendency of his criminal case. During this time, the police received information that Mr. Greenwood was again using and selling drugs at his home. The police once again conducted a search of his trash, found evidence of drug activity, and received a second search warrant to search his home based on this evidence. Once inside, they found more narcotics, and Mr. Greenwood was arrested again.
The trial court, in this case the Superior Court, dismissed, or dropped, the charges against Mr. Greenwood stating that the warrantless searches of Mr. Greenwood's trash violated the protection from unreasonable search and seizure in the Fourth Amendment of the Constitution. The government then appealed to the Court of Appeals and the California Supreme Court; both courts denied the government's claims and the case was finally appealed the United States Supreme Court.
The central component of this case was whether or not a person has a privacy expectation, or right to privacy, when it comes to their trash that they put out on the curb. Furthermore, is that expectation protected by the Fourth Amendment's search and seizure clause?
The United States Supreme Court held that there was no privacy expectation for trash left at the curb. There is also no Fourth Amendment protection because the trash is accessible to the public at large.
The U.S. Supreme Court's reasoning is that when trash is left at the curb it is 'readily accessible to animals, children, scavengers, snoops, and other members of the public~.' When something is accessible to the public, it is also accessible to law enforcement.
The Supreme Court also stated that since the trash was left at the curb, it was intended for another party (both a stranger and their trash collector) to pick up, therefore the garbage was abandoned by its original owner. Once something is left out in the open like that, it is plainly in the public view. The U.S. Supreme Court asserts that what someone knowingly exposes to the public is not granted Fourth Amendment protection from search and seizure.
California v. Greenwood established limits on what the Fourth Amendment protects from illegal searches and seizures. In this particular case, trash left out on the curb for a trash collector to pick up and throw away is not considered to have an expectation of privacy to, and therefore it is not granted Fourth Amendment protections.
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