Two police officers observed the defendant engaging in traffic violations. They stopped the defendant, who emerged from his car and approached the officers.
The first officer opened the door of the vehicle to look for the VIN (which was located on the left doorjamb on vehicles manufactured before 1969). When he did not find the VIN there, he reached into the interior of the car to move some papers obscuring the area of the dashboard where the VIN is located in later model cars. In doing so, the officer saw the handle of a gun protruding from underneath the driver’s seat. He seized the gun and arrested the defendant. The officers had no reason to suspect that the defendant’s car was stolen, that it contained contraband, or that the defendant had committed an offense other that the traffic violations.
Whether the defendant has a reasonable expectation of privacy in his vehicle’s VIN location?
No. Because of the important role played by the VIN in the pervasive government regulation of the automobile and the efforts by the government to ensure that the VIN is placed in plain view, there is no reasonable expectation of privacy in the VIN.
An automobile’s interior is protected by the Fourth Amendment’s prohibition against unreasonable intrusions by the government. However, the officer’s reaching into the vehicle to remove the papers was not an unreasonable search but was incidental to viewing something in which the defendant has no reasonable expectation of privacy. The fact that papers on the dashboard obscured the VIN from plain view did not create a reasonable expectation of privacy in the VIN.
475 U.S. 106, 106 S. Ct. 960 (1986)