Fourth Amendment: U.S. v. Navas

U.S. Court of Appeals, Second Circuit

Fourth Amendment

Trailers — Automobile Exception

U.S. v. Navas
09-1144-cr
Appealed from the Southern District of New York

Background: The appeal concerns a trailer, unhitched from its cab and parked in a warehouse. The district court held that a warrantless search of the trailer ran afoul of the Fourth Amendment. On appeal, the defendants likened the trailer to a fixed structure and argued that the district court properly suppressed the fruits of the search. The government argues that, no matter whether the trailer is attached to a cab, it is subject to a warrantless search pursuant to the “automobile exception” to the Fourth Amendment’s warrant requirement. The information leading to the defendants’ arrests was provided to the Drug Enforcement Administration by a cooperating witness who had been arrested for a narcotics-related offense. The witness informed the DEA that he was a member of a narcotics distribution enterprise that shuttled large quantities of narcotics and illicit proceeds between California and New York City. The group transported the contraband in hidden traps within trailers that contained more mundane freight.

Ruling: As the trailer was readily mobile and commanded only a diminished expectation of privacy, the court holds that the automobile exception applies, therefore the district court’s ruling is reversed.

Telemachus P. Kasulis, assistant U.S. attorney, for the appellant, and Patrick J. Joyce for appellee Navas