California v. Carney

The character of “the place to be searched”1 plays an important role in Fourth Amendment analysis. In this case, police officers searched a Dodge/Midas Mini Motor Home. The California Supreme Court correctly characterized this vehicle as a “hybrid” which combines “the mobility attribute of an automobile . . . with most of the privacy characteristics of a house.”2

The hybrid character of the motor home places it at the crossroads between the privacy interests that generally forbid warrantless invasions of the home, Payton v. New York, 445 U. S. 573, 585-590 (1980), and the law enforcement…