Ok to search Car in driveway of House because of language in Search Warrant of home(4th DCA August 7th 2019)

Price v. State, 4th DCA, August 7th, 2019.  This was an appeal from a Motion to Suppress of a large quantity of marijuana that was denied by the trial court.  The car was parked at the end of a long drive and the police had a search warrant for the "residence, curtilage, outbuildings and conveyances."  The appeals court specifically did not challenge the courts finding that the vehicle was within the curtilege because it was satisfied that the warrant said "conveyances," which is generally taken to mean vehicles.  Had the warrant not had this specific languge they may not have agreed with the lower court.  They had this to say about the application of this case to others:

We acknowledge that in Dunn v. State, 292 So. 2d 435, 435-36 (Fla. 4th DCA 1974), we reversed the denial of a motion to suppress where a vehicle parked in a driveway was searched during the execution of a search warrant for a residence and curtilage.  In Dunn, we said: “In the case at hand, there was no such evidence to connect the vehicle in question with the premises and we believe some such evidence necessary in order to authorize the search of a vehicle parked even within ‘the curtilage.’”  Id. at 436.  However, we distinguish the instant case from Dunn on the basis that unlike this case, the search warrant in Dunn authorized the search of “certain premises And [sic] the curtilage,” but said nothing about vehicles or other structures.  Id.  Similar to Dunn, the First District in Miller v. State, 516 So. 2d 1118 (Fla. 1st DCA 1987), reversed the denial of a motion to suppress the search of a vehicle after determining there was “no evidentiary connection between the residence authorized to be searched and appellants’ vehicle.”  Id. at 1119.  We again distinguish this case from Miller because in Miller, the warrant authorized “the search of the ‘premises and curtilage thereof’ for marijuana” and the warrant said nothing about vehicles or other structures.