case brief IRAC

case brief IRAC

Case brief of: New York v. Burger (U.S. Supreme Court)


1. Case Name, Citation, and Court
New York v. Burger
482 U.S. 691, 107 S. Ct. 2636, 96 L.Ed.2d 601,Web 1987 U.S. Lexis 2725
Supreme Court of the United States
Decided June 19, 1987

2. Facts
Joseph Burger was the owner of a junkyard business in Brooklyn, NY, where the business dismantled automobiles, and sold the parts. N.Y. State statute requires junkyards to keep certain records. Under the statute, a warrantless search is authorized without prior notice. A group of New York City police officers went to his business site and asked for his records of the automobiles and parts in his possession. He stated that he didn’t have those records. He also did not have a license to conduct the business, which is required under New York State law. After the inspection, police officers determined that they were stolen items. Burger was arrested and charged with criminal possession of stolen property.   He submitted a motion to suppress the evidence under the terms that the statute was unconstitutional. The motion was denied.   The court of appeals held that the statute violated Burger’s Fourth Amendment rights, and the case was reversed. New York appealed.

3. Issue
Does the warrantless search of an automobile junkyard pursuant to a state statute that authorizes such search constitute an unreasonable search and seizure in violation of the Fourth Amendment to the U.S. Constitution?

4. The Rule
The fourth Amendment prohibits unreasonable searches and seizures to commercial businesses and private homes.

5. Analysis
The Supreme Court held that:
A. Although the Fourth Amendment prohibits search and seizure to commercial premises’ and private homes, a commercial premises in a closely regulated industry has a reduced privacy
B. The New York regulatory scheme satisfies the criteria necessary to make reasonable warrantless inspections due to high vehicle theft.
C. Theft problems can be addressed...