WASHINGTON v. CHRISMAN
In 1978, a Washington police officer stopped a student at the Washington State University after observing the student was carrying a half-gallon bottle of gin. The officer asked for identification. The student, accompanied by the officer, then went into his dormitory to retrieve proof of age. After the student had entered his room, the officer noticed that the student's roommate, Chrisman, had marijuana seeds and a pipe on his desk. Chrisman was subsequently charged with the possession of marijuana and LSD.
Did the officer's seizure of the drugs violate Chrisman's "reasonable expectation of privacy" guaranteed by the Fourth Amendment?
In a 6-to-3 decision, the Court held that the "plain view" exception to the Fourth Amendment warrant requirement permitted law enforcement officers to seize clearly incriminating evidence discovered "in a place where the officer has a right to be." The Court held that the officer had a right to remain at the initial suspect's elbow at all times, and did not waive his right to custodial control because he hesitated briefly in the doorway of the dormitory room before entering. In short, the officer had obtained lawful access to an individual's area of privacy and was free to seize incriminating evidence.