Search-and-Seizure Sentence of the Day:
From Judge Gregory of the Fourth Circuit, after rejecting a defendant's claim that he had proved a reasonable expectation of privacy in an open field at least in part by being comfortable enough to urinate there:
[I]f Fourth Amendment protection were to be predicated upon where one felt comfortable enough to eliminate, our search and seizure jurisprudence would be turned on its head.
United States v. Vankesteren, n.1.

Viceroy:
it actually sounds reasonable to me - you would pick a spot to urinate or eliminate where other people aren't going to enter your space. I guess standards vary and I can see why Judge Gregory came to the conclusion he did, but I don't agree that it would necessarily "turn Fourth Amendment jurisprudence on its head".

He's guilty of hyperbole!!
1.11.2009 9:04pm
Dilan Esper (mail) (www):
By that standard, you'd have no reasonable expectation of privacy in a foul outhouse at an outdoor music festival, because nobody in their right mind would be comfortable urinating there.
1.11.2009 9:07pm
Kent G. Budge (www):
So I guess the defendant wanted the judge to void the search?
1.11.2009 9:18pm
Jim Rhoads (mail):
Scatology as jurisprudence. Nice try. Very original. But not likely to garner a grant of cert.
1.11.2009 9:44pm
Oren:
Well, he did pass the subjective "half" of the test by urinating there, so we should commend him on getting at least halfway there.
1.11.2009 9:49pm
Hadur:
Has anyone ever lost a search and seizure case because they did not have a subjective expectation of privacy that they were otherwise entitled to? E.g., perhaps somebody posted on their blog "I do not believe I am entitled to expect privacy in my basement", and then the police wanders in there and finds drugs in a drawer?
1.11.2009 9:58pm
theoldman:
Hadur, have a gander at this thread.
1.11.2009 10:05pm
Laura S.:
Dilan writes:

By that standard, you'd have no reasonable expectation of privacy in a foul outhouse at an outdoor music festival, because nobody in their right mind would be comfortable urinating there.

Before you hurt too many people: "if a then b" does not imply "if not a then not b".

As to the central issue, this judge does not seem to embody the "objective person" standard. Most people would consider a remote location where no other people are present "private".
1.11.2009 10:08pm
Hadur:
Thanks, old man.

I wonder if the "KopBuster" people, by trying to bait police into searching their property, lack a subjective expectation while having an objective one?
1.11.2009 10:15pm
Daryl Herbert (www):
one felt comfortable enough to eliminate . . . on its head

Funny stuff, Prof. Kerr.
1.11.2009 10:47pm
Mike& (mail):
Can't you people just read a sentence, get a chuckle, and move on?

I'm reminded of a new take on an old joke:

Question: How many VC commenters does it take to screw in a light bulb?
Answer: That's not funny.
1.11.2009 10:57pm
jim47:
What does the judge mean there was no expectation of privacy, defendant had clearly marked his territory!
1.11.2009 11:10pm
Sean Gleeson (mail):
Imagine what Johnny Cochran could have done with this defense: "If he took a sh*t, you must acquit!"
1.11.2009 11:39pm
Guessing (mail):
I believe Sen. Larry Craig would beg to differ.
1.11.2009 11:48pm
Cornellian (mail):
Wouldn't "evacuate" be a more precise word than "eliminate?" It isn't
actually being eliminated, just moved from one location to another.
1.12.2009 12:53am
fortyninerdweet (mail):
I'm sorry to extend this any further but have seen far too many persons urinating in open, public areas to have any sympathy with belated claims of an "expectation of privacy". That likely was the farthest thing from their minds at the time. What they wanted was an "expectation of relief" and they cared not a fig for anyone else who saw them. Btw, the judicial "head" reference was exquisite.
1.12.2009 2:58am
krs:
Sean Gleeson, crude, but thanks for my first spontaneous laugh in weeks.
1.12.2009 6:28am
JB:
Cornellian:

It's being pushed over the threshhold, "e-limin-ated." "E-vacu-ated," pushed out of a hole, also makes sense, but both have clear latin support.
1.12.2009 7:41am
krs:
Scatology as jurisprudence. Nice try. Very original

Call Prof. Fairman. I see another SSRN game in the works. I'm sure there's some journal somewhere that will publish an article titled "Poop." Or "Shit" if one wants to be regarded as just a bit more edgy.
1.12.2009 8:41am
Patent Lawyer:
Mike&-

Not quite the right punch line for that joke.

Q: How many Volokh commenters does it take to screw in a light bulb?

A: Well, if we look to the 6th Circuit's search &seizure jurisprudence, they've never answered the question squarely, but...
1.12.2009 8:59am
Awesome-O:
I'm reminded of a new take on an old joke:

Question: How many VC commenters does it take to screw in a light bulb?


Answer: legalize marijuana.
1.12.2009 9:25am
gran habano:
Q: How many Volokh commenters does it take to screw in a light bulb?

A: That would depend on whether Holder's intervention in JD careerists' decisions concerning pardons ventured beyond the safe constitutional harbor provided for executive action, assuming the principle of the unitary executive remains apart from the current strains of jurisprudence, thus precluding it from consideration as normative.

We remain agnostic on both Holder and light bulb maintenance.
1.12.2009 10:12am
Al Maviva:
I'm surprised that the nictitator Vankestern (pronounced "Van-Keestern"?) didn't bring that appeal as a John Doe.
1.12.2009 10:19am
JohnKT (mail):
All this because a farmer trapped doves and hawks on his own fields?

Do judicial proceedings wander like internet discussions?

What next in the annals of crime? Illegal dove trapping indeed.

Good grief.
1.12.2009 10:29am
Don de Drain:
I think any defendant making this kind of argument runs the risk of getting the judge "pissed off".
1.12.2009 11:58am
Bill Mullins (mail):
"Can't you people just read a sentence, get a chuckle, and move on? "

For some, the joke just whizzed right on by.
1.12.2009 12:25pm
TLove (mail):
Changes in technology have made, and will further make, any expectation of privacy unreasonable (infrared scanning through walls, etc.)

Thus the rule ought to be human perception unaided by technology. If you have to use a gizmo, you have to get a search warrant.
1.12.2009 1:22pm
Awesome-O:
Thus the rule ought to be human perception unaided by technology. If you have to use a gizmo, you have to get a search warrant.

The "gizmo" standard seems to be a good start, but...

Are binoculars a gizmo?

Infrared scanning is just the transformation of invisible light into visible light. So maybe the rule should be anything that transforms invisible light is a "gizmo."

How about night vision equipment? Much like binoculars, it magnifies visible light, so I don't know if it's a "gizmo" or not.
1.12.2009 1:28pm
TLove (mail):
Re gizmos, yes any gizmo (simple rule to understand)

except for gizmos that merely allow me not to have to move physically to another spot that I can also lawfully be at without a search warrant.

Public park - I am surveying a public park with binoculars. I can move to the spot the binoculars effectively put me in without a search warrant so yes, I can use binoculars in that instance.
Audio amplifiers - same deal.

Infra red - there is no equivalent to human unaided senses, so no, unless the public park idea applies. That is, I am guarding a public park at night.

Wire tap. no. Xray. no. Infra red to see through a wall when I would need a warrant to enter the building. No. Get a warrant.

Intercepting email. Absolutely no.
1.12.2009 1:57pm
Awesome-O:
except for gizmos that merely allow me not to have to move physically to another spot that I can also lawfully be at without a search warrant.

Interesting. I assume you're aware that this is a departure from current law. I'm guessing that you're being proscriptive rather than descriptive.

The problem with the "gizmo" standard is that it's incongruent with the reasonable expectation of privacy standard, and thus could impose requirements on the police that private citizens do not face. Sure, today we expect privacy where we could only be seen with infrared equipment. But there could come a day when everyone's cell phone comes standard with an infrared camera. It would be hard to expect privacy when everyone could take pictures of the IR radiation leaving our homes, and yet the police would be required to get a warrant.
1.12.2009 2:09pm
Oren:

It would be hard to expect privacy when everyone could take pictures of the IR radiation leaving our homes, and yet the police would be required to get a warrant.


It's eminently reasonable for me to assume that, even if my neighbor had an IR camera, he would refrain from pointing at my house to spy on me. That is to say, there is a strong social, not technological, constraint that prevents normal people from spying on what others do in the privacy of their own homes.

Cell phone cameras are quite common and can easily be concealed in a pocket with just the lens showing (mine can even operate in video mode to obviate the need for any human intervention either). Nevertheless, despite the extreme technical ease of doing so, it's still quite unreasonable to photograph someone in a locker room because social custom identifies the locker room as a private place.

Link2
Link
1.12.2009 2:56pm
Awesome-O:
It's eminently reasonable for me to assume that, even if my neighbor had an IR camera, he would refrain from pointing at my house to spy on me.

...today.

But when everone has a camera, and where IR photography of homes is a wildly popular hobby engaged in by millions, then it's no longer so reasonable.
1.12.2009 4:53pm
Toby:
In a future post, Awesome-O defends Up-Skirt web sites as reasonable.
1.12.2009 5:32pm
Awesome-O:
In a future post, Awesome-O defends Up-Skirt web sites as reasonable.

The websites are fine.

Photographing unwitting women or Scots is not fine as long as there are statutes against that sort of thing, and currently there are.
1.12.2009 5:58pm
Brian G (mail) (www):

Imagine what Johnny Cochran could have done with this defense: "If he took a sh*t, you must acquit!"


Ditto the other guy, Sean. Thanks for the laugh that I certainly needed.
1.12.2009 7:51pm
Michael Ejercito (mail) (www):

From Judge Gregory of the Fourth Circuit, after rejecting a defendant's claim that he had proved a reasonable expectation of privacy in an open field at least in part by being comfortable enough to urinate there:

[I]f Fourth Amendment protection were to be predicated upon where one felt comfortable enough to eliminate, our search and seizure jurisprudence would be turned on its head.

This was a no-brainer.
1.13.2009 6:08pm
Michael Ejercito (mail) (www):

It's eminently reasonable for me to assume that, even if my neighbor had an IR camera, he would refrain from pointing at my house to spy on me. That is to say, there is a strong social, not technological, constraint that prevents normal people from spying on what others do in the privacy of their own homes.

Do IR cameras work passively or actively?

A device that only detects radiation coming out of the house can be used for surveillance without abridging Fourth Amendment guarantees.

Something like radar or sonar (which rely on signals emitted from the device) may violate the Fourth Amendment guarantees.
1.13.2009 6:12pm
markm (mail):
JohnKT:

Illegal dove trapping indeed.

John, the charge was trapping hawks. The doves (quite likely domestic rather than wild)were presumably bait for the hawk trap, and thus their presence was evidence.
1.13.2009 6:46pm

Post as: [Register] [Log In]

Account:
Password:
Remember info?

If you have a comment about spelling, typos, or format errors, please e-mail the poster directly rather than posting a comment.

Comment Policy: We reserve the right to edit or delete comments, and in extreme cases to ban commenters, at our discretion. Comments must be relevant and civil (and, especially, free of name-calling). We think of comment threads like dinner parties at our homes. If you make the party unpleasant for us or for others, we'd rather you went elsewhere. We're happy to see a wide range of viewpoints, but we want all of them to be expressed as politely as possible.

We realize that such a comment policy can never be evenly enforced, because we can't possibly monitor every comment equally well. Hundreds of comments are posted every day here, and we don't read them all. Those we read, we read with different degrees of attention, and in different moods. We try to be fair, but we make no promises.

And remember, it's a big Internet. If you think we were mistaken in removing your post (or, in extreme cases, in removing you) -- or if you prefer a more free-for-all approach -- there are surely plenty of ways you can still get your views out.