Agnello v. United States
269 U.S. 20 (1925)
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Rule of Law:
A warrantless search of a private residence is not constitutionally permissible as incident to a lawful arrest when the search is remote in time or place from the arrest. Evidence obtained from such an unconstitutional search is inadmissible against the victim of the search under the Fifth Amendment.
Facts:
- Government agents used informants to arrange a cocaine purchase from Stephen Alba and Antonio Centorino at Alba's home.
- Centorino left Alba's home to get the drugs, going first to his own house and then to a building where Frank Agnello lived.
- Centorino, Thomas Pace, and the Agnello brothers returned to Alba's house to conduct the sale.
- At Alba's house, Frank Agnello produced packages of cocaine for delivery to the informants in exchange for money.
- Upon the apparent completion of the sale, revenue agents who were watching the house rushed in and arrested all the defendants present.
- After the defendants were arrested and taken into custody, some of the agents went to Frank Agnello's home, located several blocks away.
- The agents searched Agnello's home without a search warrant and discovered a can of cocaine in his bedroom.
Procedural Posture:
- Frank Agnello and his co-conspirators were indicted in the U.S. District Court for the Eastern District of New York for conspiracy to sell cocaine.
- At trial, the government attempted to introduce a can of cocaine seized from Agnello's home, but the court initially excluded it as the product of a warrantless search.
- After Agnello testified, the trial court permitted the government to introduce the previously excluded evidence for rebuttal purposes, over the defendants' objection.
- The jury convicted all defendants.
- The defendants appealed to the U.S. Circuit Court of Appeals, which affirmed the convictions.
- The U.S. Supreme Court granted certiorari to review the case.
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Issue:
Does a warrantless search of a defendant's home, conducted after the defendant has been arrested at a different location, violate the Fourth Amendment, and is evidence seized during that search admissible at trial?
Opinions:
Majority - Mr. Justice Butler
Yes. A warrantless search of a defendant's home conducted at a location remote from where he was arrested violates the Fourth Amendment, and evidence obtained from that search is inadmissible. The right to conduct a warrantless search incident to a lawful arrest extends only to the place where the arrest is made and must be contemporaneous with it. This exception allows officers to seize weapons or evidence connected with the crime at the scene of the arrest. Frank Agnello's house was several blocks away from Alba's house where the arrest occurred, and the search took place after the defendants were already in custody. Therefore, the search cannot be justified as an incident of the arrest. A search of a private dwelling without a warrant is presumptively unreasonable, and a belief that contraband is concealed within, however well-founded, does not justify foregoing the warrant requirement. Because the search violated the Fourth Amendment, the evidence seized (the can of cocaine) was inadmissible against Agnello under the Fifth Amendment's protection against self-incrimination, as established by the exclusionary rule. The evidence cannot be admitted in rebuttal, as Agnello did not testify about the can of cocaine on direct examination, and the essence of the exclusionary rule is that such evidence shall not be used at all.
Analysis:
This case firmly establishes the spatial and temporal limits of the search-incident-to-arrest doctrine, clarifying that the exception is not a roving commission to search any property a suspect owns. It reinforces the heightened Fourth Amendment protection afforded to a private dwelling, holding that a warrant is required for a home search unless an exception is strictly met at the location itself. This decision curtails law enforcement's ability to conduct broad, exploratory searches following an arrest and solidifies the application of the exclusionary rule to evidence obtained from such overreaching searches, preventing its use even for impeachment purposes when the defendant has not opened the door to the topic.
