Josephs v. Commonwealth

390 S.E.2d 491, 10 Va. App. 87, 6 Va. Law Rep. 1803, 1990 Va. App. LEXIS 48
CourtCourt of Appeals of Virginia
DecidedMarch 27, 1990
DocketRecord No. 0423-87-2
StatusPublished
Cited by195 cases

This text of 390 S.E.2d 491 (Josephs v. Commonwealth) is published on Counsel Stack Legal Research, covering Court of Appeals of Virginia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Josephs v. Commonwealth, 390 S.E.2d 491, 10 Va. App. 87, 6 Va. Law Rep. 1803, 1990 Va. App. LEXIS 48 (Va. Ct. App. 1990).

Opinions

Barrow, J.,

with whom Benton, J. and Coleman, J. join, dissenting.

The majority fails to distinguish between Josephs’ standing to challenge a search of an automobile in which she was riding and her standing to challenge a stop of the same automobile. A passenger in an automobile has no standing to challenge its search where he or she can assert neither a proprietary nor a possessory interest in the automobile. Rakas v. Illinois, 439 U.S. 128, 148-49 (1978). It, therefore, follows that a passenger in a stolen automobile, in which he or she has no proprietary or possessory interest, has no standing to challenge the legality of a search of the automobile. United States v. Hargrove, 647 F.2d 411, 413 (4th Cir. 1981); see also Rakas, 439 U.S. at 142 n.9. It does not, however, follow that a thief has no standing to challenge the seizure of his or her person while riding as a passenger in a stolen vehicle.

A person has “standing” to assert fourth amendment rights only if he or she is asserting the violation of his or her own rights, not those of someone else. Jones v. United States, 362 U.S. 257, [103]*103261 (1960). A passenger or a thief who has no proprietary or possessory interest in an automobile in which he is riding and, consequently, has no “legitimate expectation of privacy in the particular areas of the automobile searched,” therefore, lacks standing to question the legality of the search of the automobile. Rakas, 439 U.S. at 148 (emphasis added). Unquestionably, this defendant had no legitimate expectation of privacy in the trunk of the automobile she was convicted of stealing. See id. at 148-49.

The question in this case, however, is whether Josephs has standing to question the legality of her detention while riding in a car which she later was convicted of having stolen. The detention may prove to be legal, depending upon whether the police reasonably suspected that the car was stolen or some other criminal conduct was underway, but the threshold issue is whether Josephs can question the reasonableness of that suspicion. The answer to this question depends on whether Josephs is asserting violation of her own fourth amendment rights or those of someone else. Rakas, 439 U.S. at 143.

An unreasonable seizure of a person violates the fourth amendment. Terry v. Ohio, 392 U.S. 1, 9 (1968). The fourth amendment, in addition to limiting the power of the police to search “houses, papers, and effects,” protects the “right of the people to be secure in their persons.” U.S. Const, amend. IV. The Supreme Court has always recognized “the right of every individual to the possession and control of his own person, free from all restraint or interference of others, unless by clear and unquestionable authority of law.” Terry, 392 U.S. at 9 (quoting Union Pac. Ry. v. Botsford, 141 U.S. 250, 251 (1891)). An occupant of a car stopped by the police is entitled to the same fourth amendment protection as is a person stopped on the street. See Delaware v. Prouse, 440 U.S. 648, 663 (1979) (decided after Rakas). A police stop of an automobile is a seizure of the car’s occupants. Id. at 653; Simmons v. Commonwealth, 238 Va. 200, 202, 380 S.E.2d 656, 658 (1989). This conclusion flows from an occupant’s right to be secure in his or her person, see Prouse, 440 U.S. at 654, not from an expectation of privacy in the automobile.

The four dissenting and two concurring justices in the Rakas decision expressly recognized this distinction. See 4 W. LaFave, Search and Seizure § 11.3(b), at 294-95 (2d ed. 1987). Justice White, joined by Justices Brennan, Marshall and Stevens, pointed [104]*104out in his dissent that the “petitioners of course have standing to challenge the legality of the stop, and the evidence found may be a fruit of that stop . . . Petitioners have not argued that theory here.” Rakas, 439 U.S. at 160 n.5. Justice Powell, joined by Chief Justice Burger, observed in his concurring opinion that “[t]he petitioners do not challenge the constitutionality of the police action in stopping the automobile in which they were riding; nor do they complain of being made to get out of the vehicle.” Rakas, 439 U.S. at 150-51.

After Rakas, other courts, perceiving the difference between a passenger’s standing to object to a search of a car in which he or she is riding and his or her standing to question the legality of his or her detention while riding in an automobile, have concluded that a passenger in an automobile has standing to object to the seizure, regardless of the passenger’s lack of proprietary or possessory interest in the vehicle. See, e.g., State v. Haworth, 106 Idaho 405, 406, 679 P.2d 1123, 1124 (1984); State v. Eis, 348 N.W.2d 224, 225 (Iowa 1984); State v. DeMasi, 419 A.2d 285, 294 (R.I. 1980), vacated, 452 U.S. 934 (1981); State v. Guzy, 139 Wis. 2d 663, _ 407 N.W.2d 548, 553, cert. denied, 484 U.S. 979 (1987); Parkhurst v. State, 628 P.2d 1369, 1374 (Wyo.), cert. denied, 454 U.S. 899 (1981). These decisions recognize that stopping a motor vehicle and detaining its occupants is a seizure of the occupants within the meaning of the fourth and fourteenth amendments. See State v. Conger, 183 Conn. 386,_, 439 A.2d 381, 384 (1981); see also Prouse, 440 U.S. at 653; Haworth, 106 Idaho at 406, 679 P.2d at 1124; Guzy, 139 Wis. 2d at-, 407 N.W.2d at 553. Although a passenger may not possess the requisite reasonable expectation of privacy in the seized vehicle, “no one has ever challenged the existence of such in regard to one’s own person.” Parkhurst, 628 P.2d at 1374; see also Eis, 348 N.W.2d at 226 (“no principled basis exists for distinguishing between the privacy rights of passengers and drivers in a moving vehicle”); DeMasi, 419 A.2d at 294 (“the occupants of a moving automobile retain a reasonable interest in personal privacy”); see 4 W. LaFave, supra, § 11.3(e), at 325 (“[Sjurely the passenger has standing to object”).

Those cases which have determined that a passenger lacks standing to contest a seizure “are founded on a broad stroke analysis of Rakas as simply holding that passengers lack standing to contest government action as to the vehicle.” People v. Jones, 125 [105]*105Misc. 2d 91, 95-96, 477 N.Y.S.2d 975, 979 (N.Y. Sup. Ct. 1984). See, e.g., State v. Cowen, 104 Idaho 649, 651, 662 P.2d 230, 232 (1983); Haworth, 106 Idaho at 406, 679 P.2d at 1124; Meeks v. State, 692 S.W.2d 504, 510 (Tex. Crim. App. 1985); United States v. Cardona, 524 F. Supp. 45, 47 (W.D. Tex. 1981). The reasoning of these cases is unpersuasive because the cases fail to distinguish between standing to object to a search and standing to object to a seizure, which results in the search that follows.

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Bluebook (online)
390 S.E.2d 491, 10 Va. App. 87, 6 Va. Law Rep. 1803, 1990 Va. App. LEXIS 48, Counsel Stack Legal Research, https://law.counselstack.com/opinion/josephs-v-commonwealth-vactapp-1990.