David Davalos v. United States

The Fourth Amendment “draw[s] a firm line at the entrance” to the home, which includes its curtilage. Payton v. New York, 445 U.S. 573, 590 (1980); see also Florida v. Jardines, 569 U.S. 1, 6 (2013). Absent “exigent circumstances,” a police officer cannot “enter a home or its curtilage in order to search a vehicle therein” without a warrant. Collins v. Virginia, 584 U.S. 586, 601 (2018). And “application of the exigent-circumstances exception in the context of a home entry should rarely be sanctioned when there is probable cause to believe that only a minor offense … has been committed.” Welsh v. Wisconsin, 466 U.S. 740, 753 (1984). Rather, the case-bycase inquiry requires that the “totality of circumstances shows an emergency.” Lange v. California, 594 U.S. 295, 308 (2021). The questions presented are:

1. Whether a portion of a driveway immediately adjacent to a home is curtilage under the Fourth Amendment.

2. Whether a parked car’s tinted windows categorically qualify as an exigent circumstance to justify an officer’s warrantless entry onto the home’s curtilage and search of the vehicle.