The Oyez Project: Criminal Procedure Issues - Search And Seizure, Vehicles Decisions

Adams v. Williams

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Alabama v. White

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Almeida-Sanchez v. United States

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Arizona v. Evans

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Arkansas v. Sanders

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

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."

Atwater v. City of Lago Vista

Does the Fourth Amendment, either by incorporating common-law restrictions on misdemeanor arrests or otherwise, limit a police officer's authority to arrest without warrant for minor criminal offenses?

No. In a 5-4 opinion delivered by Justice David H. Souter, the Court held that the Fourth Amendment does not forbid a warrantless arrest for a minor criminal offense, such as a misdemeanor seatbelt violation punishable only by a fine. "If an officer has probable cause to believe that an individual has committed even a very minor criminal offense in his presence, he may, without violating the Fourth Amendment, arrest the offender," wrote Justice Souter for the Court. Justice Sandra Day O'Connor's dissenting opinion argued that the Court's decision "neglects the Fourth Amendment's express command in the name of administrative ease" and thus "cloaks the pointless indignity that Gail Atwater suffered with the mantle of reasonableness."

Brower v. Inyo County

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Cady v. Dombrowski

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California v. Acevedo

Under the Fourth Amendment, may police conduct a warrantless search of a container within an automobile if they have probable cause to believe that the container holds evidence?

Yes. In a 6-3 decision authored by Justice Harry Blackmun, the Court reversed the Court of Appeal and ruled that the "automobile exception" to the Fourth Amendment's general search-warrant requirement is broad enough to cover a situation where the police only have probable cause to believe there is evidence in a specific movable container within the car. The Court noted that the warrant requirement previously had depended on a "curious line between the search of an automobile that coincidentally turns up a container and the search of a container that coincidentally turns up in an automobile." In place of that uncertain distinction, the Court adopted a single rule: "The police may search an automobile and the containers within it where they have probable cause to believe contraband or evidence is contained." Justices White, Stevens, and Marshall dissented.

California v. Carney

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Cardwell v. Lewis

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Chambers v. Maroney

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City of Indianapolis v. Edmond

Are highway checkpoint programs, whose primary purpose is the discovery and interdiction of illegal narcotics, consistent with the Fourth Amendment?

No. In a 6-3 opinion delivered by Justice Sandra Day O'Connor, the Court held that because the checkpoint program's primary purpose was indistinguishable from the general interest in crime control, the checkpoints violated the Fourth Amendment. "We cannot sanction stops justified only by the generalized and ever-present possibility that interrogation and inspection may reveal that any given motorist has committed some crime," wrote Justice O'Connor. Chief Justice William H. Rehnquist and Justices Antonin Scalia and Clarence Thomas dissented, arguing that the reasonableness of the city's roadblocks depended on whether they served a "significant state interest with minimal intrusion on motorists."

Colorado v. Bertine

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Coolidge v. New Hampshire

Did the searches of Coolidge's home and automobile violate the Fourth Amendment?

In a decision in which a number of justices chose to concur in part and dissent in part, the Court held that the searches and seizures of Coolidge's property were unconstitutional. Justice Stewart's opinion held that the warrant authorizing the seizure of Coolidge's automobile was invalid because it was not issued by a "neutral and detatched magistrate." Stewart also rejected New Hampshire's arguments in favor of making an exception to the warrant requirement. Stewart held that neither the "incident to arrest" doctrine nor the "plain view" doctrine justified the search, and that an "automobile exception" was inapplicable.

Cooper v. California

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Delaware v. Prouse

Did the officer's search of Prouse's automobile constitute an unreasonable search and seizure under the Fourth Amendment?

Yes. In an 8-to-1 decision, the Court held that the privacy interests of travelers outweighed the state interests in discretionary spot checks of automobiles. The Court found that random checks made only marginal contributions to roadway safety and compliance with registration requirements; less intrusive means could have been used to serve the same ends. Officers must be held to a "probable cause" standard for searches, otherwise individuals would be subject to "unfettered governmental intrusion" each time they entered an automobile.

Fahy v. Connecticut

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Florida v. Bostick

Is the acquisition of evidence during random bus searches, conducted pursuant to passengers' consent, a per se violation of the Fourth Amendment's protection against unconstitutional search and seizure?

No. The Court, in a 6-to-3 decision, noted that when deciding if a search request is overly coercive, within a confined space such as a bus, one must not look at whether a party felt "free to leave," but whether a party felt free to decline or terminate the search encounter. The Court held that in the absence of intimidation or harassment, Bostick could have refused the search request. Moreover, the fact that he knew the search would produce contraband had no bearing on whether his consent was voluntarily obtained. The test of whether a "reasonable person" felt free to decline or terminate a search presupposes his or her innocence.

Florida v. Jimeno

Does a suspect's consent to a search of his vehicle extend to closed containers found inside?

Yes. In a 7-to-2 decision, the Supreme Court held that the search did not violate the Fourth Amendment's prohibition of unreasonable searches. "The touchstone of the Fourth Amendment is reasonableness," wrote Chief Justice William H. Rehnquist in the majority opinion. "We think it was objectively reasonable for the police to conclude that the general consent to search respondent's car included consent to search containers within that car which might bear drugs. A reasonable person may be expected to know that narcotics are generally carried in some form of a container."

Florida v. Meyers

Was the Court's summary disposition of the case constitutionally legitimate?

In a per curiam opinion, a majority of the Court held that the Florida court had misapplied the law and that a warrantless search of the automobile was permissible since the vehicle was already in police custody. The dissenting opinion, written by Justice Stevens, argued that the Supreme Court's decision to bypass the Florida Supreme Court judgment and to consider the case was ill-advised. Justice Stevens maintained that summarily disposing of such cases unduly enlarged the Supreme Court's responsibilities and deemed state judges incompetent to decide Fourth Amendment questions.

Florida v. Wells

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Florida v. White

Does the Fourth Amendment require the police to obtain a warrant before seizing an automobile from a public place when they have probable cause to believe that it is forfeitable contraband under the Florida Contraband Forfeiture Act?

No. In a 7-2 opinion delivered by Justice Clarence Thomas, the Court held that the Fourth Amendment does not require the police to obtain a warrant before seizing an automobile from a public place when they have probable cause to believe that it is forfeitable contraband. Thomas wrote: "Although the police here lacked probable cause to believe that [White's] car contained contraband, they had probable cause to believe that the vehicle itself was contraband under Florida law. ... [T]he need to seize readily movable contraband before it is spirited away...is equally weighty when the automobile, as opposed to its contents, is the contraband that the police seek to secure." In dissenting, Justices John Paul Stevens and Ruth Bader Ginsburg concluded that the seizure was not reasonable without a warrant.

Gustafson v. Florida

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Harris v. United States

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Illinois v. Caballes

Does the Fourth Amendment's search and seizure clause require a reasonable articulable suspicion to conduct a canine sniff during a routine traffic stop?

Justice John Paul Stevens delivered the Court's 7-2 opinion that Caballes' Fourth Amendment rights were not violated. The Constitution did not require police to have reasonable suspicion to use a drug-detection dog on a car during a legal traffic stop. No legitimate privacy was at risk, the Court argued, because the dog only alerted to an illegal drug.

Illinois v. Lidster

Does Indianapolis v. Edmond, which dealt with the Fourth and 14th Amendment prohibitions of unreasonable searches and seizures, prohibit checkpoints organized to question motorists about a previous offense and arrest motorists for drunk driving?

No. In an opinion delivered by Justice Breyer, the Court held 6-3 that the Illinois checkpoint did not violate the Fourth Amendment's prohibition of unreasonable searches and seizures and was constitutional. It ruled that the checkpoint was reasonable because it advanced a "grave" public interest - "investigating a crime that had resulted in a human death" - and interfered minimally with Fourth Amendment liberty. The Court distinguished Illinois's "information-seeking" checkpoint from the "crime control" checkpoint struck down in Edmond. Justices Stevens, Souter, and Ginsburg - while agreeing that Edmond does not invalidate the Illinois checkpoint - dissented from the majority's decision granting constitutional approval to the checkpoint. They argued that the case should have been remanded to the Illinois courts.

Knowles v. Iowa

Can a search of a stopped vehicle, that occurs prior to the driver's arrest, be sustained under the "search incident to arrest" exception that permits officers to search stopped vehicles without first obtaining a search warrant?

No. In a unanimous opinion that Court held that full stopped-car searches can only be conducted when the safety of the officers is at risk. One significant indication of such danger is when an officer arrests the subject as a reaction to possible or actual threat. In the present case, no serious danger accompanied the stop of Knowles car as evidenced by the officer's initial decision not to arrest Knowles or even issue him a ticket. As such, regardless of its uncovered contents, the subsequent search violated the "search incident to arrest" power and the Fourth Amendment's prohibition again unlawful search and seizures.

Maryland v. Dyson

Does the Fourth Amendment require police to obtain a search warrant before searching a vehicle which they have probable cause to believe contains illegal drugs?

No. In a per curiam opinion, the Court held that the decision of the Maryland Court of Special Appeals rested upon an incorrect interpretation of the automobile exception to the warrant requirement of the Fourth Amendment. The Court reasoned that, because the automobile exception has no separate exigency requirement and where there is probable cause to search an automobile, a search is not unreasonable if based on facts that would justify the issuance of a warrant, even though a warrant is not actually obtained. Justice Stephen G. Breyer, joined by Justice John Paul Stevens, dissented.

Maryland v. Pringle

Does an arrest of a front-seat passenger in a car driven by its owner, after police find cocaine in the car's back armrest, lack probable cause and violate the Fourth Amendment's prohibition of unreasonable searches and seizures?

No. In a unanimous opinion delivered by Chief Justice William Rehnquist, the Court ruled that because the officer had probable cause to arrest Pringle, the arrest did not violate the Fourth Amendment. The Court reasoned that "a reasonable officer could conclude that there was probable cause to believe that Pringle committed the crime of possession of cocaine."

Maryland v. Wilson

Did Maryland's state trooper violate the Fourth Amendment's search and seizure guarantees by ordering Wilson, a mere passenger in the suspect vehicle, to exit the car during a traffic stop?

No. The Court held that after lawfully stopping a speeding vehicle, an officer may order its passengers to step out. While burdening their personal liberty somewhat, officers must be permitted such authority over passengers if the overriding government's interest in officer safety is to be protected.

Massachusetts v. White

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Michigan Department of State Police v. Sitz

Did the drunk driving checkpoints violate motorists' privacy protected by the Fourth Amendment?

In a 6-to-3 decision, the Court held that the roadblocks did not violate the Fourth Amendment. The Court noted that "no one can seriously dispute the magnitude of the drunken driving problem or the States' interest in eradicating it." The Court then found that "the weight bearing on the other scale--the measure of the intrusion on motorists stopped briefly at sobriety checkpoints--is slight." The Court also found that empirical evidence supported the effectiveness of the program.

New York v. Belton

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New York v. Class

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Ohio v. Robinette

Does the Fourth Amendment's protection against illegal search and seizures require that a lawfully detained defendant be told that he is "free to go" before he can be said to have voluntarily agreed to any subsequent search?

No. After establishing its federal jurisdiction, despite a claim that the matter involved aspects of Ohio's Constitution, the Court held that when looking at the totality of the circumstances it may be reasonably concluded that if a defendant consents to be searched, even if not first advised that he is "free to go," the ensuing search will be recognized as voluntary. The Court also added that Robinette's arrest on drug possession charges was lawful, even though the arresting officer did not stop him on an initial suspicion of drug possession nor intend to even issue him a speeding ticket.

Oklahoma v. Castleberry

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Pennsylvania v. Labron

Does the Fourth Amendment, as applied to the States through the Fourteenth, require police to obtain a warrant before searching an automobile unless exigent circumstances are present?

No. In a 7-2 per curiam opinion, the Court held that if a vehicle is readily mobile and probable cause exists to believe it contains contraband, the Fourth Amendment permits police to search the vehicle and contraband seized from such a search should not be suppressed. The Court noted that early cases establishing the automobile exception were based on the automobile's ready mobility, an exigency sufficient to excuse failure to obtain a search warrant once probable cause to conduct the search is clear. Justice John Paul Stevens, who was joined by Justine Ruth Bader Ginsburg, dissented.

Plymouth Sedan v. Pennsylvania

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Rakas v. Illinois

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Rios v. United States

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Robbins v. California

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Schneckloth v. Bustamonte

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South Dakota v. Opperman

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Texas v. Brown

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Texas v. White

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Thornton v. United States

Under the "search incident to arrest" exception to the Fourth Amendment, may police search the vehicle of a person they have arrested if they did not make contact with him until after he left the vehicle?

Yes. In a 7-to-2 decision, the Court ruled that forcing officers to decide whether a suspect had noticed them before exiting the car (with the understanding that only if he had could the car be searched) would be too subjective and leave officers uncertain of whether they could perform searches. Further, it found that weapons or contraband inside a vehicle could still be easily accessed by someone who had just exited it, providing the same reason for searching the vehicle that was present in cases where suspects were arrested while still inside it (that is, the possibility that illegal material would be destroyed or officers attacked with concealed weapons). Chief Justice Rehnquist, in the majority opinion, wrote, "Once an officer determines there is probable cause to make an arrest, it is reasonable to allow officers to ensure their safety and to preserve evidence by searching the entire passenger compartment."

United States v. Brignoni-Ponce

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United States v. Chadwick

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United States v. Cortez

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United States v. Flores-Montano

Does the Fourth Amendment require customs officers at the international border to have reasonable suspicion in order to remove, disassemble, and search a vehicle's gas tank for illegal material?

No. In a unanimous opinion delivered by Chief Justice William Rehnquist, the Court held that the government had authority to inspect a vehicle's fuel tank at the border without suspicion. Though the Fourth Amendment "'protects property as well as privacy,'" interference with a vehicle owner's gas tank "is justified by the Government's paramount interest in protecting the border." The Court rejected the argument that the requirement of suspicion for highly intrusive searches of people be carried over to cars (especially at the border): "Complex balancing tests...have no place in border searches of vehicles."

United States v. Johns

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United States v. Martinez-Fuerte

Do such stops violate the Fourth Amendment's proscription against unreasonable searches and seizures?

No, because if there is a reasonable collective suspicion, then individuals can be searched in the interest of public safety. Justice Lewis F. Powell, Jr., writing for the 7-to-2 majority, said: "The defendants note correctly that to accommodate public and private interests some quantum of individualized suspicion is usually a prerequisite to a constitutional search or seizure.... But the Fourth Amendment imposes no irreducible requirement of such suspicion."

Prepared by Michael Brandow.

United States v. Ortiz

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United States v. Padilla

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United States v. Robinson

Did the officer's search violate the Fourth Amendment?

The Court upheld the search. Distinguishing between searches done to discover concealed weapons and those conducted coextensive with an arrest, Justice Rehnquist argued since the officer did not conduct the search in an abusive or extreme manner, and because he acted consistent with the authority vested in a police officer when making an arrest, his actions were legitimate.

United States v. Ross

Did the police violate the Fourth Amendment?

The Court held that since the search was done with probable cause and extended into the realm (Ross's car) of which a magistrate issuing a warrant would have approved, the officers did not violate the Fourth Amendment. Justice Stevens defended the search of the vehicle's trunk, arguing that if probable cause justifies a vehicle search, then every part of the vehicle is open to inspection.

United States v. Watson

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Whiteley v. Warden

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Whren v. United States

Did the officers conduct an unreasonable search and seizure in violation of the Fourth Amendment?

No. The unanimous Court held that as long as officers have a reasonable cause to believe that a traffic violation occurred, they may stop any vehicle. In the present case, the officers had reasonable cause to stop the petitioners for a traffic violation since they sped away from a stop sign at an 'unreasonable speed' and without using their turn signal. Thus, since an actual traffic violation occurred, the ensuing search and seizure of the offending vehicle was reasonable, regardless of what other personal motivations the officers might have had for stopping the vehicle. Furthermore, the Court rejected the claim that the anxiety, confusion, and haste which the petitioners experienced from the stop-and-search outweighed the government's interest in traffic safety. While the Fourth Amendment does require a balancing test between a search-and-seizure's benefits and the harm it might cause to the individual, such a test only applies to unusually harmful searches and seizures. There was nothing unusually harmful about this traffic stop.

Wyoming v. Houghton

May police officers, with probable cause to search a car, inspect personal items belonging to its passengers without violating the Fourth Amendment's protection against unreasonable searches?

Yes. In a 6-to-3 decision the Court held that so long as there is probable cause to search a stopped vehicle, all subsequent searches of its contents are legal as well. The Court added that such searches are especially warranted if aimed at looking into objects or personal belongings capable of concealing items that are the object of the search.