ABSTRACT
U.S. courts generally have interpreted the Fourth Amendment to the Constitution as requiring officials to obtain warrants to conduct governmental searches. Several factors are considered in determining whether an area is part of a dwelling's curtilage. The open-fields doctrine came into its own as part of an expanded government effort to conduct the war on drugs during the 1970s and 1980s. In one of the early cases, Oliver v. United States, 466 US 170 (1984), the US Supreme Court established that there was no expectation of privacy in open fields, where police had discovered marijuana growing. In United States v. Dunn, 480 US 294, the Court further stated that open fields need be neither "open" nor a "field" as these concepts are commonly used. The Court also maintained that a state may provide greater search and seizure protection than is available under the Fourth Amendment, the latter being merely a threshold minimum protection that states must observe.
