In the 1924 case Hester v. United States, the Supreme Court made a distinction between so-called “open fields” and the areas afforded protection under the Fourth Amendment. This Amendment provides that “[t]he right of the people to be secure in their persons, houses, papers, and effects, against unreasonable searches and seizures, shall not be violated…” U.S. Const. amend. IV.  While not explicitly using the word “curtilage,” Justice Holmes refers to a distinction between the “special protection” given by the Fourth Amendment to the people [to be secure] in their 'persons, houses, papers and effects,'” and that this protection is not extended to the open fields. Hester v. United States, 265 U.S. 57, 59 (1924).