People v. Sciacca, 45 N.Y.2d 122 (1978)
A warrant to search a vehicle does not automatically authorize entry onto private property, such as a locked garage, to access the vehicle, and such an entry, absent exigent circumstances or specific authorization in the warrant, violates the Fourth Amendment.
Summary
Sciacca was convicted of possessing and transporting untaxed cigarettes after tax investigators, acting on a warrant to search his van, entered a locked garage where it was parked and discovered contraband. The New York Court of Appeals affirmed the Appellate Division’s reversal of the conviction, holding that the warrant authorizing the search of the van did not authorize the warrantless entry into a private, locked garage. The court reasoned that the investigators exceeded the scope of the warrant and violated Sciacca’s reasonable expectation of privacy. The ‘inevitable discovery’ doctrine did not apply in this case where the constitutional violation was not merely technical.
Facts
The New York State Tax Enforcement Bureau received information that John Sciacca was smuggling untaxed cigarettes using a green Dodge van. Surveillance confirmed Sciacca’s activities, including transporting boxes resembling cigarette cartons. Based on this, investigators obtained a warrant to search the van. After Sciacca parked the van in a locked garage, investigators, without obtaining a warrant to enter the garage, moved a loose panel, entered, and found 3,060 cartons of untaxed cigarettes inside the van.
Procedural History
Sciacca was convicted at trial after his motion to suppress the evidence was denied. The Appellate Division reversed the conviction, finding the entry into the garage an unreasonable search and seizure. The People appealed to the New York Court of Appeals, which affirmed the Appellate Division’s decision.
Issue(s)
Whether a warrant authorizing the search of a vehicle extends the authority of law enforcement to enter a private, locked garage to access that vehicle.
Holding
No, because the warrant authorized the search of a particular van and nothing else, and the garage had a structural and functional existence distinct from the van; therefore, the investigators’ entry into the garage was unlawful. The theory of inevitable discovery does not apply to excuse the unlawful entry.
Court’s Reasoning
The court reasoned that a warrant must particularly describe the place to be searched, and authority to search a vehicle does not imply authority to enter private premises. The investigators’ entry into the locked garage constituted an unreasonable search because Sciacca had a reasonable expectation of privacy within the garage. The court distinguished cases where vehicles were searched in driveways or open carports, finding that a locked garage provides a greater expectation of privacy. The court emphasized that the investigators knew of Sciacca’s use of the garage and could have sought a warrant to enter it. The court rejected the argument that the entry was justified by the need to inspect regulated activity, stating that regulatory schemes cannot override constitutional safeguards. The court quoted Colonnade Corp. v. United States, noting that “our traditions are strongly opposed to using force without definite authority to break into a locked premises.” The court also dismissed the inevitable discovery argument, stating that the constitutional violation was not a mere technicality. “The theory of inevitable discovery is essentially a safety valve for the exclusionary rule to be used when the constitutional violation is of technical dimension and should not be used to countenance the breaking into a locked garage by administrative investigators.”