TN: An RV parked off the property but connected by an electrical cord to the house was subject to search under a warrant for the house

To search vehicles under a search warrant for real property, the vehicles must belong to a person named in the warrant to identify the place or things to be searched. Vehicles belonging to visitors are not subject to search under the warrant. “Generally, then, a search conducted pursuant to a warrant for the search of premises but encompassing a vehicle not particularly described in the warrant may be justified when the vehicle is: (1) located on the premises described; and (2) within the possession or control of persons named in the warrant.” An RV off the property but tethered to it by an electrical cord running from the house is subject to search. State v. Thompson, 2015 Tenn. Crim. App. LEXIS 272 (April 15, 2015):

We conclude that, although the RV was not parked on the premises, the fact that it was parked in the area immediately beside the home and attached by an electrical cord to the home creates a sufficient nexus to validate the search under the warrant. The RV belonged to the owner of the property, was parked in a private area immediately adjacent to the premises described in the warrant, and was further associated with the premises through the use of an electrical cord tethering the RV to the home. By attaching the RV to the residence, the defendant created a “place[], which [was] appurtenant to the described building and … under the control of persons named in the warrant.” Worden, 273 S.W.2d at 141; cf. State v. Courtright, 298 S.E.2d 740, 741, 742-43 (N.C. App. 1983) (concluding that search of vehicle whose tires projected six or seven inches into the yard was valid because the vehicle extended into the curtilage).