Sunday, May 17, 2009

Oliver v. United States, 466 U.S. 170 (1984)

Facts

Kentucky agents went to Oliver’s house on reports that marijuana was being raised on the farm.  Agents walked past posted “No Trespassing” signs and found a field of marijuana over a mile from Oliver’s home.

Procedural History

Oliver was charged with manufacturing a controlled substance and the district Court suppressed evidence of the marijuana field discovery.  The Court of Appeals reversed.

Issue(s)

Is evidence obtained through an unwarranted police search of a privately owned open field inadmissible in a criminal trial?

Holding(s)

No.

Reasoning/Analysis

The Court found in Hester, it was held that the special protection accorded to people in their persons, houses, papers, and effects does not extend to open fields.  The rule from Hester may be understood as providing that an individual may not legitimately demand privacy for activities conducted out of doors in fields, except in the area immediately surrounding the home.  The test of legitimacy is not whether the individual chooses to conceal assertedly private activity.  Rather, the correct inquiry is whether the government’s intrusion infringes upon the personal and societal values protected by the Fourth Amendment.

Judgment/Outcome

The Court affirmed the judgment of the Court of Appeals.

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