California v. Carney

When a vehicle is being used on highways or is capable of that use and is found stationary in a place not regularly used for residential purposes, two justifications for the vehicle exception to the warrant requirement came into play. First, that the vehicle is readily mobile. Second, there is a reduced expectation of privacy stemming from the pervasive regulation of vehicles. Under these circumstances, the overriding societal interests in effective law enforcement justify an immediate search before the vehicle and its occupants become mobile.

In this case, the defendant’s vehicle possessed many attributes of a home. However, the vehicle falls clearly within the scope of the automobile exception since the defendant’s motor home was readily mobile. While the vehicle is capable of functioning as a home, to distinguish between a motor home and a typical car would require that the mobile conveyance exception be applied depending upon the size of the vehicle and the quality of its appointments. The Court was not willing to make this distinction. Therefore, under the mobile conveyance exception to the warrant requirement, the search of the defendant’s motor home was reasonable.