California v. Greenwood
Year: 1988
Result: 6-2, favor California
Related Constitutional issue/Amendment: 4th Amendment (unreasonable search and seizure)
Civil rights or Civil liberties: Civil liberties
Significance/precedent: The significance of this case is the specification that garbage is not private property protected by the 4th Amendment from unreasonable searches and seizures. Once Greenwood had placed his trash on the street, any person would have been free to search it, even if they were not government affiliated.
Quote from majority opinion: "Here, we conclude that respondents exposed their garbage to the public sufficiently to defeat their claim to Fourth Amendment protection. It is common knowledge that plastic garbage bags left on or at the side of a public street are readily accessible to animals, children, scavengers, snoops, and other members of the public. Moreover, respondents placed their refuse at the curb for the express purpose of conveying it to a third party, the trash collector, who might himself have sorted through respondents' trash or permitted others, such as the police, to do so. Accordingly, having deposited their garbage in an area particularly suited for public inspection and, in a manner of speaking, public consumption, for the express purpose of having strangers take it, respondents could have had no reasonable expectation of privacy in the inculpatory items that they discarded."
Summary of dissent: There was not probable cause for the uncivilized searches of Greenwood’s trash. Also, since the trash could be considered a “closed package” the police would have been required by the 4th Amendment to obtain a warrant before rummaging through the garbage.
6-word summary: Trash not protected from searches, seizures
Result: 6-2, favor California
Related Constitutional issue/Amendment: 4th Amendment (unreasonable search and seizure)
Civil rights or Civil liberties: Civil liberties
Significance/precedent: The significance of this case is the specification that garbage is not private property protected by the 4th Amendment from unreasonable searches and seizures. Once Greenwood had placed his trash on the street, any person would have been free to search it, even if they were not government affiliated.
Quote from majority opinion: "Here, we conclude that respondents exposed their garbage to the public sufficiently to defeat their claim to Fourth Amendment protection. It is common knowledge that plastic garbage bags left on or at the side of a public street are readily accessible to animals, children, scavengers, snoops, and other members of the public. Moreover, respondents placed their refuse at the curb for the express purpose of conveying it to a third party, the trash collector, who might himself have sorted through respondents' trash or permitted others, such as the police, to do so. Accordingly, having deposited their garbage in an area particularly suited for public inspection and, in a manner of speaking, public consumption, for the express purpose of having strangers take it, respondents could have had no reasonable expectation of privacy in the inculpatory items that they discarded."
Summary of dissent: There was not probable cause for the uncivilized searches of Greenwood’s trash. Also, since the trash could be considered a “closed package” the police would have been required by the 4th Amendment to obtain a warrant before rummaging through the garbage.
6-word summary: Trash not protected from searches, seizures