Arkansas v. Sanders
442 U.S. 753 (1979)
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Rule of Law:
The Fourth Amendment's warrant requirement applies to personal luggage taken from an automobile. The automobile exception does not justify the warrantless search of personal luggage seized from a lawfully stopped vehicle once the luggage is in the exclusive control of law enforcement and no exigent circumstances exist.
Facts:
- An informant told Little Rock police that Lonnie Sanders would arrive at the airport with a green suitcase containing marijuana.
- Police observed Sanders arrive, retrieve a green suitcase from baggage claim, and meet a companion, David Rambo.
- Sanders placed hand luggage into a waiting taxicab and gave the green suitcase to Rambo.
- Rambo placed the green suitcase in the trunk of the taxi, after which both he and Sanders got into the vehicle.
- The taxi drove away from the airport with Sanders, Rambo, and the suitcase.
- Police officers stopped the taxi several blocks from the airport.
- At the officers' request, the taxi driver opened the trunk, revealing the green suitcase.
- Without permission, the police opened the unlocked suitcase and discovered 9.3 pounds of marijuana.
Procedural Posture:
- Lonnie Sanders was charged with possession of marihuana with intent to deliver in an Arkansas state trial court.
- Before trial, Sanders filed a motion to suppress the evidence obtained from the suitcase, alleging an unconstitutional search.
- The trial court denied the suppression motion.
- Following a trial, a jury convicted Sanders.
- Sanders appealed to the Supreme Court of Arkansas.
- The Supreme Court of Arkansas, the state's highest court, reversed the conviction, holding that the evidence should have been suppressed because the warrantless search of the suitcase was unlawful.
- The State of Arkansas successfully petitioned the U.S. Supreme Court for a writ of certiorari.
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Issue:
Does the warrantless search of personal luggage seized from a lawfully stopped automobile violate the Fourth and Fourteenth Amendments when police have probable cause to believe the luggage contains contraband but no exigent circumstances exist?
Opinions:
Majority - Justice Powell
Yes. The warrantless search of personal luggage seized from a lawfully stopped automobile violates the Fourth and Fourteenth Amendments where no exigent circumstances are present. The Fourth Amendment protects a significant expectation of privacy in personal luggage which is not diminished simply because it is placed in an automobile. The two justifications for the automobile exception—inherent mobility and a reduced expectation of privacy—do not apply to luggage once it is seized by police and brought under their exclusive control. At that point, the exigency of mobility is eliminated, as there is no danger the luggage or its contents will be removed before a warrant can be obtained. Therefore, absent another applicable exception, police must obtain a warrant before searching the contents of the luggage.
Concurring - Chief Justice Burger
Yes. A warrant was required because the police had probable cause focused specifically on the suitcase before it was ever placed in the vehicle. This case is controlled by United States v. Chadwick, not the automobile exception, as the relationship between the luggage and the vehicle was purely coincidental. The Court's opinion is unnecessarily broad by delving into the automobile exception, as this case does not present the question of whether a warrant is required when police have probable cause to believe contraband is located somewhere in a vehicle but not in a specific container.
Dissenting - Justice Blackmun
No. The warrantless search of personal luggage seized from a lawfully stopped automobile does not violate the Fourth Amendment. The Court's decision extends the flawed logic of United States v. Chadwick and creates greater confusion for law enforcement. A clear-cut rule should be adopted stating that any personal property found in an automobile that may be lawfully seized and searched without a warrant should also be searchable without a warrant. The expectation of privacy in a suitcase found in a car is not significantly greater than in a locked glove compartment or trunk, and the majority's distinction between different types of containers will create impractical line-drawing problems for officers in the field.
Analysis:
This decision solidified the distinction between the constitutional protections afforded to automobiles and to personal containers found within them. It affirmed that a person's heightened expectation of privacy in their luggage is not forfeited by placing it in a vehicle. The ruling created what became known as the 'Sanders rule,' which required police to differentiate between probable cause to search a car generally and probable cause to search a specific container. This complex legal framework proved difficult to apply and was ultimately overruled by California v. Acevedo (1991), which held that police may search any container within a vehicle without a warrant if they have probable cause to believe contraband or evidence is located within that container.
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