California v. Ciraolo
Citation and Court
476 U.S. 207 (1986) — Supreme Court of the United States
Facts
Acting on an anonymous tip, police obtained a private plane and flew over Ciraolo’s house at 1,000 feet—within navigable airspace—and observed marijuana plants growing in his fenced backyard. They obtained a warrant based on the aerial observations and seized the plants. Ciraolo argued the warrantless aerial observation of his curtilage violated the Fourth Amendment.
Issue
Is the warrantless aerial observation of marijuana plants growing in the curtilage of a home from navigable airspace a Fourth Amendment search?
Holding
No; aerial observation of a home’s curtilage from publicly navigable airspace does not constitute a search because there is no reasonable expectation of privacy against observation by aircraft flying at lawful altitudes.
Rule / Doctrine
The Fourth Amendment protects against unreasonable searches and seizures, but it does not protect what is knowingly exposed to the public. If an area is visible to any member of the public traveling through publicly navigable airspace, there is no reasonable expectation of privacy, even if the area is within the curtilage of a home.
Significance
Ciraolo is a significant curtilage case establishing that the home’s protected zone does not extend vertically to block aerial observation from navigable airspace. It is often paired with Florida v. Riley (helicopter surveillance) and stands for the principle that the Fourth Amendment’s protection of the home and curtilage has limits when exposure to the public is considered.