Saturday, June 18, 2011

Eleventh Circuit holds that officers entering a closing garage violated the Fourth Amendment

Two Sheriff's deputies attempted to serve a restraining order to John Coffin, as personal service was required by Florida law. However, after being told to leave the property by Coffin's wife, the deputies entered the household garage which Ms. Coffin was attempting to close. The deputies arrested Ms. Coffin for obstruction. The Coffins then sought damages against the deputies under 42 U.S.C. § 1983 on the grounds that the deputies' warrantless entry into their garage and arrest of Ms. Coffin violated their Fourth Amendment rights. The Eleventh Circuit held that the deputies violated the Fourth Amendment, but were entitled to qualified immunity.

On April 18, 2006 in Sarasota County, Fl., Sheriff's deputy James Lutz attempted to serve Mr. John Coffin with a Temporary Injunction Against Repeat Violence. The injunction was obtained by one of Mr. Coffin's tenants, and Florida law required that such injunctions be served in person by law enforcement officers.

In attempting service, Deputy Lutz knocked on the front door of the Coffins' home. Ms. Coffin answered and Deputy Lutz explained that he had important documents to deliver to Mr. Coffin. Ms. Coffin replied that her husband was in the bathroom and that Deputy Lutz would have to wait to speak to her husband. Ms. Coffin closed and locked the door. After several minutes, Deputy Lutz believed he made eye contact with Ms. Coffin from through a window. He waved the paperwork in the air to remind Ms. Coffin that he was still waiting.

After a few additional minutes of waiting and believing he heard Mr. Coffin speaking inside, Lutz walked up to a window to try and get the Coffins' attention. Ms. Coffin, upset by Lutz walking on her bushes, "began shouting for him to get out of her bushes and off her property and threatened to call the police."

Lutz went to his patrol car, which was parked on the street. He called for backup, and a few minutes later Deputy Stacy Brandau arrived on the scene. Ms. Coffin then briefly opened a door from the interior of the house and pressed a button to shut the automatic main door of the adjoining garage. The garage shared the same roof as the house, was physically adjoined to the house, and all sides were closed except for the open door which faced a public street. Seeing that that door was closing, the deputies stepped into the electronic-eye safety beam - a laser beam which, if interrupted, will cause a garage door to automatically reopen as a safety precaution. The garage door reopened, the deputies entered and arrested Ms. Coffin for obstruction.

The Coffins challenged Ms. Coffin's arrest and the deputies' entrance into the garage through a lawsuit for damages against the deputies. The United States District Court for the Middle District of Florida held that the deputies violated the Fourth Amendment by entering the garage, but because the rule of law was not clearly established, the deputies were entitled to qualified immunity for their entry into the garage and their arrest of Ms. Coffin. A three-member panel of the United States Court of Appeals for the Eleventh Circuit affirmed the district court's decision. The court of appeals then vacated its own decision to rehear the matter en banc, before a full panel of twelve judges.

In the en banc hearing, the Coffins maintained that an attached garage is part of "the unambiguous physical dimensions" of a home and therefore entitled to the same extensive Fourth Amendment protections that a home has. The Coffins further argued that such a violation was clearly unlawful and that the deputies should be stripped of their immunity from suit. The deputies countered that the rule was not clearly established and thus they were entitled to immunity for their actions.
The court of appeals first analyzed whether the Coffins' garage was generally entitled to Fourth Amendment protections. Precedent had established that closed and locked garages were protected by the Fourth Amendment, and that officers who, without a warrant, entered the front door of a home, proceeded through the dwelling area, and then entered an adjoining garage violated the Fourth Amendment. However, the Coffin's garage was open, and the deputies maintained that they entered the garage in order to knock on a door to the interior of the home, which was in the garage and which Ms. Coffin had just used. This situation was distinguishable from established Fourth Amendment case law and the court of appeals declined to answer whether a previously open garage which is joined to a home is generally entitled to Fourth Amendment protections.

Instead, the court of appeals ruled that the deputies violated the Fourth Amendment rights of the Coffins because they had expressed a clear intent to maintain their privacy and exclude the deputies from the property. Ms. Coffin attempted to exercise her Fourth Amendment rights when she closed and locked her door after telling Deputy Lutz that he would have to wait to speak to Mr. Coffin. Then, when Ms. Coffin noticed Lutz walking through her bushes, she instructed him to leave the property and threatened to call the local police. Finally, and "most significantly, when Lutz and Brandau remained on the property, Ms. Coffin attempted to close the garage door in order to maintain privacy in that area as well." Since Ms. Coffin's efforts to maintain privacy were clear, the deputies' entry into the garage was in violation of the Fourth Amendment.

Even so, the court of appeals held that the deputies were entitled to qualified immunity for five reasons. First, there was no binding precedent which would have clearly forbidden the deputies from entering an open garage. Second, the protections afforded to an open garage were ambiguous. Third, the law regarding invasion of privacy is heavily reliant on case-specific facts and thus the law is rarely well-established. Fourth, the statutory requirement that the injunction be served personally by a law enforcement officer gave the deputies reason to believe they were acting lawfully. Finally, the deputies had an arguably reasonable belief that Ms. Coffin was obstructing the service of an injunction and thus has sufficient reason to arrest her.

To review the full decision, click here.

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