New York v. Class

In New York v. Class, 475 U.S. 106 (1986), the Supreme Court determined that in light of the important role VIN's play in the pervasive governmental regulation of automobiles, a "motorist must surely expect that . . . regulation will on occasion require the State to determine the VIN of his or her vehicle." Id. at 113. This fact, coupled with the diminished expectation of privacy inherent in automobiles generally, led the Supreme Court to hold that there is no reasonable expectation of privacy in a VIN. Class, 475 U.S. at 114. However, the evidence introduced against Class was not the VIN, but a weapon discovered during the officer's inspection of the VIN. Thus, the Supreme Court went on to analyze whether the actions by the officer in reaching into the automobile were constitutionally permissible. The Court discussed the various safety concerns inherent in a traffic stop, and balanced the governmental interest against that of the individual. The Court noted that the safety of the officers was served by the governmental intrusion, the intrusion was minimal, and the search stemmed from some probable cause focusing suspicion on the individual affected by the search. Class, 475 U.S. at 117-18. Based on the facts of the case, the Court held: "The search was sufficiently unintrusive to be constitutionally permissible in light of the lack of a reasonable expectation of privacy in the VIN and the fact that the officers observed respondent commit two traffic violations. Any other conclusion would expose police officers to potentially grave risks without significantly reducing the intrusiveness of the ultimate conduct--viewing the VIN--which, as we have said, the officers are entitled to do as part of an undoubtedly justified traffic stop." Id. at 119.