holding that, based on facts where “the similarities [to Mimms] [were] strong enough that the balancing of governmental interests against governmental intrusion undertaken in those cases [was] also appropriate,” a search was reasonable where the search “was focused in its objective and no more intrusive than necessary to fulfill that objective.”
How later courts described this case
- holding that, based on facts where “the similarities [to Mimms] [were] strong enough that the balancing of governmental interests against governmental intrusion undertaken in those cases [was] also appropriate,” a search was reasonable where the search “was focused in its objective and no more intrusive than necessary to fulfill that objective.”
- holding that Fourth Amendment was not violated where, during an “undoubtedly justified traffic stop” an officer observed the vehicle’s vehicle identification number (VIN), which “is by law present in one of two locations—either inside the doorjamb, or atop the dashboard and thus ordinarily in plain view of someone outside the automobile”
- holding that “as part of an undoubtedly justified traffic stop,” officers checking for the VIN in order to run a search is “sufficiently unintrusive to be constitutionally permissible in light of the lack of a reasonable expectation of privacy in the VIN”
- explaining that a “State’s intrusion into a particular area, whether in an automobile or elsewhere, cannot result in a Fourth Amendment violation unless the area is one in which there is a constitutionally protected reasonable expectation of privacy”
Written by the judges who cited it.
Later courts went against this
Declined to follow by United States v. Caro, 248 F.3d 1240 (2001)
We decline to extend Class in this manner.
Distinguished
Distinguished by United States v. Harry Katzin, 732 F.3d 187 (2013)
A brief look at the underlying reasoning of Class, however, demonstrates that it is inapposite: the Court reasoned that the brief search served several important government needs beyond a basic interest in law enforcement, including "the governmental interest in highway safety” and a "concern for the officers’ safety.
The opinion
Justice White,
with whom Justice Stevens joins, dissenting.
The police officer involved in this case entered the interior of respondent’s automobile, an area protected by the Fourth Amendment against unreasonable searches and seizures. A car may be searched without a warrant if there is probable cause to do so, but no one suggests that this precondition for a search existed here. The entry was solely to remove an obstruction that prevented the VIN from being seen from outside the car. The issue is whether the governmental interest in obtaining the VIN by entering a protected area is sufficient to outweigh the owner’s privacy interest in the interior of the car. I am unprepared, at least for the reasons the Court gives, to conclude that it is.
Had Class remained in his car and refused an officer’s order (1) to turn over his registration certificate and (2) to remove the article obscuring the VIN, there would have been no more justification for entering the interior of the car and doing what was necessary to read the VIN than there would have been to enter and search for the registration certificate in the glove compartment. It may be that under our cases, Class could have been sanctioned for his refusal in such a case, but we have never held that his refusal would permit a search of the glove compartment. Even if it did, it would be different if there was no refusal at all, but just an entry to *132 find a registration certificate. If that is the case, this one is no different in kind: there was no refusal and nothing but a nonconsensual entry to search without probable cause and without emergent circumstances.
It makes no difference that the law requires the VIN to be visible from outside the car. Otherwise, a requirement that the VIN be carried in a prominent location in the trunk of the car would justify searches of that area whenever there was a stop for a traffic violation. I thus do not join the Court’s opinion, which in effect holds that a search of a car for the VIN is permissible whenever there is a legal stop, whether or not the driver is even asked to consent.
Nevertheless, Class was unlicensed and the police were not constitutionally required merely to give him a citation and let his unlicensed driving continue. Arguably, one of the officers legally could have driven the car away himself and in the process noticed the gun; the car could have been towed and inspected at the station; or Class could have been arrested for driving without a license and the entire car searched. But the Court eschews these possible alternative rationales and rests its judgment on grounds that I do not accept.