California v. Greenwood
Citation and Court
486 U.S. 35 (1988) — Supreme Court of the United States
Facts
Police received information that Billy Greenwood was involved in drug trafficking. Officers asked Greenwood’s trash collector to give them the trash bags left at the curb. Officers searched the bags and found drug paraphernalia. Based on this evidence, they obtained a warrant to search Greenwood’s home and found cocaine and hashish. Greenwood argued the warrantless search of his trash violated the Fourth Amendment.
Issue
Does the Fourth Amendment prohibit the warrantless search and seizure of garbage left in opaque bags at the curb for collection?
Holding
No; there is no reasonable expectation of privacy in garbage left at the curb for collection because the trash is exposed to the public and voluntarily conveyed to a third party (the trash collector).
Rule / Doctrine
The Fourth Amendment does not protect garbage left at the curb because (1) it is voluntarily exposed to the public and (2) when an individual knowingly exposes information or items to a third party (here, the trash collector), that person assumes the risk the third party will turn it over to the government. This is an application of the third-party doctrine.
Significance
Greenwood is the leading case on the absence of Fourth Amendment protection for curbside garbage. It is a significant application of the third-party doctrine and the “knowingly exposed to the public” principle. Its reasoning has been influential—and controversial—as courts grapple with modern privacy expectations in the digital age.