California v. Krivda

Background

Police searched the respondents’ trash and used the items found to charge them with possession of marihuana under California law section 11530. The California Supreme Court affirmed a lower court’s dismissal and suppression order, holding that the respondents had a reasonable expectation that their trash would not be rummaged through by police acting without a warrant (People v. Krivda). The United States Supreme Court granted review of that decision.

Reasoning

The central issue the Justices considered was whether the California Supreme Court based its decision on the federal Fourth and Fourteenth Amendments, on the California Constitution, or on both. The United States Supreme Court found the state opinion cited both state and federal authorities and could not tell with certainty which ground controlled. Because the Court could not determine whether the state decision rested on an adequate and independent state-law basis, it did not decide the federal constitutional question on the merits.

Real world impact

The Supreme Court vacated (cancelled) the California court’s judgment and sent the case back to the California Supreme Court to clarify the legal grounds for its ruling. That means the national court left unresolved whether federal constitutional protections apply to police searches of trash. The outcome could still change after the California court explains whether it relied only on state law or on federal law as well.