The United States Supreme Court has authorized exterior searches for vehicle identification numbers (VIN). This issue was analyzed in New York v. Class, 475 U.S. 106 (1986). In this case, New York City police officers stopped a vehicle for speeding. The vehicle also had a cracked windshied which is a violation of New York law. The defendant exited the vehicle and provided the police with proof of registration and insurance but no driver’s license.One of the officers involved in the stop opened the door to examine the VIN, which was located on the left doorjamb of the vehicle. When the officer did not find the VIN there, he reached into the interior of the car in order to move some papers that were obstructing the area of the dashboard where the VIN is located on late model automobiles. When the officer did so, the officer saw the handle of a gun protruding from under the driver’s seat. The weapon was immediately seized and the defendant was arrested.
The Supreme Court held that the VIN is a vital component in the regulation of automobiles. As such, motorists should expect a substantially diminished expectation of privacy in the VIN numbers to their vehicles. This is especially true of a driver who has committed a traffic violation. Since the VIN is generally accessible and visible from the exterior of the vehicle, an examination may not even constitute a search. Since there is no expectation of privacy in the VIN, no showing of probable cause or reasonable suspicion of a violation of law is necessary for an examination from the exterior of the vehicle for this number. The Supreme Court found that it makes no difference that papers in the defendant’s car obscured the VIN number from plain view. The Court held that efforts to restrict access to a particular area do not generate a reasonable expectation of privacy where none would otherwise exist.