State Of Louisiana v. James A. Charles

Supreme Court of Louisiana
November 19, 2025
Chief Deputy Clerk of Court
For the Court
The Supreme Court of the State of Louisiana
STATE OF LOUISIANA
VS.
JAMES A. CHARLES
No. 2025-KK-00816
_ _
_ _ _ _
I
N RE: State of Louisiana - Applicant Plaintiff; Applying For Writ Of Certiorari,
Parish of St. Landry, 27th Judicial District Court Number(s) 23-00668, Court of
Appeal, Third Circuit, Number(s) KW 25-00201;
_ _ _ _ _ _
November 19, 2025
Writ application granted. See per curiam.
Weimer, C.J., additionally concurs and assigns reasons.
Hughes, J., dissents and would grant and docket.
Griffin, J., dissents.
Guidry, J., dissents and assigns reasons.
WJC
JLW
JBM
CRC
11/19/2025 "See News Release 051 for any Concurrences and/or Dissents."

SUPREME COURT OF LOUISIANA
No. 2025-KK-00816
STATE OF LOUISIANA
VS.
JAMES A. CHARLES
On Writ of Certiorari to the Court of Appeal, Third Circuit, Parish of St. Landry
PER CURIAM
Writ granted. The court of appeal erred in reversing the trial court’s judgment
denying defendant’s motion to suppress. Finding the subject vehicle was not in the
curtilage of defendant’s home, we hold the seizure and search of the vehicle were
reasonable and reinstate the trial court’s ruling.
Responding to a reported shooting, Opelousas police officers spoke with an
eye witness who identified the shooter a s James Charles. The witness confirmed
Charles was driving a silver car and lived in a mobile home in a trailer park on
Montgomery Lane. The shooting victim likewise confirmed the shooter was a man
driving a silver car.
Officers went to the trailer park and found the described mobile home with a
silver car parked next to it. A license plate check confirmed the car was registered
to “Wilbert James Charles.” The car, which had visible bullet holes and a flat tire,
was parked between the trailer and a gravel access road into the trailer park. The
area was not enclosed, had no fencing or signs, and additional vehicles were parked
nearby. Other trailers were in close proximity, and n othing visibly designated
parking areas for each trailer.
Officers knocked on the front door and got no response but heard movement
inside the home. An officer then walked over to the silver car , wiped dew off the

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window, and, cupping her hands to the window, looked in the car and saw empty
shell casings on the seat. She did not open the car’s doors, and it was not searched
at the scene. Instead, the vehicle was towed to a police lot where it was later searched
after a warrant was issued. The officer testified it was not safe to search the vehicle
at the scene because they were investigating a domestic shooting, people were inside
the trailer, and the driver of the vehicle may have still been armed and dangerous.
After the vehicle was searched pursuant to a warrant, the empty shell casings were
collected as evidence. Defendant was eventually arrested and charged with
attempted first degree murder, aggravated assault, and felon in possession of a
firearm.
Defendant filed a motion to suppress the empty shell casings, arguing the
vehicle was searched and seized without a warrant. Defendant maintains an
unlawful search occurred when the officer l ooked in the vehicle’s window, after
wiping dew off the glass, while the vehicle was parked within the curtilage of the
house. A warrantless seizure likewise occurred when the vehicle was towed.
Defendant relied on jurisprudence holding that a vehicle within the curtilage of a
home does not fall within the general au tomobile exception to the warrant
requirement. See Collins v. Virginia, 584 U.S. 586, 601; 138 S.Ct. 1663, 1675; 201
L.Ed.2d 9 (2018). The state countered that the vehicle was not parked in the home’s
curtilage but was in a communal, unmarked, and unenclosed parking area.
The trial court denied the motion to suppress, but the court of appeal reversed,
finding “the search was conducted within the curtilage of the home.” See State v.
James, KW 25 -00201 (La. App. 3 Cir. 4/17/25) (unpublished writ action). We
disagree.
The curtilage of a home is that “area to which extends the intimate activity
associated with the sanctity of a man’s home and the privacies of life.” United States
v. Dunn, 480 U.S. 294, 107 S.Ct. 1134, 94 L.Ed.2d 326 (1987). The area must be

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“so intimately tied to the home itself that it should be placed under the home’s
umbrella of Fourth Amendment protection.” Dunn, 480 U.S. at 301; 107 S.Ct. at
1134. Four considerations are useful in making this determination: the proximity of
the area to the home, whether the area is included within an enclosure surrounding
the home, the nature of the uses to which the area is put, and the steps taken by the
resident to protect the area from observation by people passing by. Id.
The court of appeal based its curtilage determination entirely on the proximity
of the car to the trailer. The remaining Dunn factors all indicate the car was not inside
the home’s curtilage. The car was not parked in an enclosure surrounding the home,
no steps were taken to protect the area from view, and it was not visibly identified
for, or otherwise restricted to, parking exclusively for defendant’s residence. Based
on the evidence, the area was not “so intimately tied to the home itself that it should
be placed under the home’s umbrella of Fourth Amendment protection.” See Dunn,
480 U.S. at 301; 107 S.Ct. at 1134; see also State v. Brown, 395 So. 2d 1301, 1310
(La. 1981) (no reasonable expectation of privacy in driveway area of a residence
where no evidence established property was fenced or driveway had a gate); State v.
Washington, 591 So.2d 1388, 1390 (La. App. 4 Cir. 1991) (no reasonable
expectation of privacy in apartment complex common area easily accessible by the
general public).
The court of appeal relied on Collins, which is factually distinguishable.
There, a motorbike was covered by a tarp and parked at the top of a driveway in a
partially enclosed area behind and abutting the front of the house. See Collins, 584
U.S. at 593; 138 S.Ct. at 1670-71. Here, the area was not enclosed or marked in any
manner and the car was not under a tarp.
The officers had probable cause to search and seize the car given the
information they knew at the time. Because the car was not in the home’s curtilage,
a warrant was not required to search and seize the vehicle under several exceptions

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to the warrant requirement. 1 The trial court did not abuse its discretion in denying
the motion to suppress.
COURT OF APPEAL JUDGMENT REVERSED; TRIAL COURT
JUDGMENT REINSTATED.

1 See Maryland v. Dyson, 527 U.S. 465, 466; 119 S.Ct. 2013, 2014; 144 L.Ed.2d 442 (1999)
(automobile exception); Chambers v. Maroney, 399 U.S. 42; 90 S.Ct. 1975, 1981; 26 L.Ed.2d 419
(1970) (automobile exception); Horton v. California , 496 U.S. 128, 130; 110 S.Ct. 2301, 2304;
110 L.Ed.2d 112 (1990) (plain view); State v. Hilton, 16-0325 (La. 3/24/16), 187 So. 3d 981, 982
(plain view); Roaden v. Kentucky, 413 U.S. 496, 93 S.Ct. 2796, 37 L.Ed.2d 757 (1973) (exigent
circumstances); State v. Brisban , 00 -3437 (La. 2/26/02) , 809 So.2d 923, 927 (exigent
circumstances). Although the officer had to wipe dew from the car’s window to see inside, this
action is analogous to shining a flashlight into an automobile at night. See State v. Edsall, 385 So.
2d 207, 210 (La. 1980) (Officer was entitled as a precaution for his own safety to generally survey
vehicle, although he had to step on the side of the truck to shine his flashlight into its cab.)