California v. Greenwood
California v. Greenwood is a significant legal case decided by the U.S. Supreme Court in the late 1980s that addresses the balance between privacy rights and law enforcement practices under the Fourth Amendment. The case originated when police in Laguna Beach, California, investigated Billy Greenwood on suspicions of drug-related activities but lacked sufficient evidence for a search warrant. Instead, they sought and obtained his discarded trash from a collection service, which led to the discovery of incriminating evidence against him.
Greenwood argued that he had a reasonable expectation of privacy regarding the contents of his trash, despite it being placed at the curb. However, the Supreme Court concluded that his expectation was not reasonable, as the trash was accessible to the public and could be examined by anyone. This ruling effectively allowed law enforcement greater leeway in conducting searches without warrants in certain contexts, especially concerning items discarded in public spaces. The decision has had lasting implications for privacy rights and the legal standards surrounding search and seizure, contributing to ongoing discussions about individual rights and law enforcement authority in the United States.
California v. Greenwood
The Case: U.S. Supreme Court decision on warrantless searches
Date: Decided on May 16, 1988
Significance: This case expanded the ability of all levels of law-enforcement bodies to conduct searches, without judicial warrants, for things in which persons are considered to have no “reasonable expectation of privacy”—such as garbage left out for collection.
In 1984, police in Laguna Beach, California, received information that a man named Billy Greenwood was selling drugs out of his home. However, there was not sufficient evidence for the police to obtain a warrant to search Greenwood’s home. Consequently, the police asked the local trash collection company to turn over to them garbage that they collected from Greenwood’s house.
Greenwood was in the habit of leaving his garbage in opaque plastic bags at the curbside in front of his house. When officers searched the bags that had been collected at this house, they found evidence of illegal drug use. Citing that evidence, they obtained a warrant to search Greenwood’s house, in which they found hard evidence of drug trafficking and then arrested Greenwood. While Greenwood was out on bail, officers searched his garbage again, found more incriminating evidence, obtained a second search warrant, and eventually arrested Greenwood on additional charges.
During Greenwood’s ensuing criminal trial, the court found that the searches of his trash bags without a warrant were illegal. Without the evidence obtained from the trash, there would have been no probable cause to obtain the search warrants. Therefore, under what is known as the “fruit of the poisonous tree” doctrine, the warrants were invalid, and the charges against Greenwood were dropped. The state of California then appealed the decision to a higher court but lost. The state’s own supreme court did not agree to hear the case, but the U.S. Supreme Court did because the case touched on an issue of broad national importance.
In previous cases, the Supreme Court had held that the Fourth Amendment to the U.S. Constitution requires police to obtain search warrants when subjects of their investigations have a “reasonable expectation of privacy” in the places or items to be searched. In Katz v. United States (1967), for example, the Court had held that a person had a reasonable expectation of privacy in the content of a phone conversation he had conducted in a public phone booth.
In the Greenwood case, the defendant argued that he had a reasonable expectation of privacy in the contents of his trash bags. Although the opaque bags were placed on a public street, Greenwood argued that he did not suppose that anyone was likely to inspect the contents of those bags. He assumed that, as always, his trash would be picked up by the trash company and mingled with that of his neighbors. However, a majority of justices on the Supreme Court ruled that while Greenwood might have expected that his garbage was private, that was not a reasonable expectation, as anyone—“animals, children, scavengers, [or] snoops”—could have gone through the contents of his trash bags after he placed them on the curb. The Court’s ruling in his case, therefore, narrowed the range of searches for which law-enforcement officers had to obtain search warrants, thereby making it easier to collect evidence.
Bibliography
Kennedy, Caroline, and Ellen Alderman. The Right to Privacy. New York: Vintage, 1997.
Sykes, Charles. The End of Privacy: The Attack on Personal Rights at Home, at Work, On-Line, and in Court. New York: St. Martin’s Griffin, 2000.