Facts of the Case

Local police in Little Rock, Arkansas received a tip that an individual would be arriving at the airport with a suitcase containing a significant quantity of marijuana. Upon arriving, the suspect retrieved his suitcase and left in a taxi. The police officers pursued and stopped the taxi, and ordered the driver to open the trunk which revealed the suitcase in question. The police opened the suitcase without obtaining permission from its owner and found nearly ten pounds of marijuana.

Question

Did the warrantless search of the suitcase by the police violate the Fourth and Fourteenth Amendments which prohibit unreasonable searches?

Conclusion

Yes. The Court held that the Fourth Amendment's warrant requirement applies to personal luggage taken from an automobile. In this case, Justice Powell applied the principle which the Court had identified in United States v. Chadwick (1977), namely, that a locked footlocker which had been loaded into a vehicle could not be opened without a warrant. Since the Little Rock police officers had exclusive control of the luggage at the time of their search, there was no danger that its contents could have been tampered with or removed before a valid warrant could have been obtained. Powell concluded that since "luggage is a common repository of one's personal effects" it is "associated with the expectation of privacy."