California v. Acevedo
500 U.S. 565 (1991)
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Rule of Law:
The Fourth Amendment permits police to conduct a warrantless search of a container within an automobile if they have probable cause to believe that the container holds contraband or evidence, even if they lack probable cause to search the entire vehicle.
Facts:
- A federal drug agent in Hawaii informed Officer Coleman of the Santa Ana Police that a package containing marijuana was being sent to a J.R. Daza in Santa Ana.
- The agent sent the package to Coleman, who verified its contents and arranged for a controlled delivery at a Federal Express office.
- Police observed Jamie Daza claim the package, take it to his apartment, and later discard the packaging materials in a trash bin.
- Officers then saw another man, Richard St. George, leave the apartment with a knapsack, and a search of the knapsack revealed marijuana.
- Shortly after, Charles Steven Acevedo entered Daza's apartment, stayed for about 10 minutes, and emerged carrying a brown paper bag that appeared full and was the size of one of the original marijuana packages.
- Acevedo placed the paper bag in the trunk of his car and began to drive away.
- Believing the bag contained marijuana, officers stopped Acevedo's car, opened the trunk, and opened the bag, finding marijuana inside.
Procedural Posture:
- Charles Steven Acevedo was charged in a California state trial court with possession of marijuana for sale.
- Acevedo filed a motion to suppress the marijuana evidence, which the trial court denied.
- Acevedo pleaded guilty but appealed the trial court's denial of his suppression motion to the California Court of Appeal, Fourth District.
- The Court of Appeal (intermediate appellate court) reversed the trial court's decision, ruling that the marijuana should have been suppressed because officers lacked a warrant to search the bag.
- The Supreme Court of California (state's highest court) denied the State of California's petition for review.
- The State of California successfully petitioned the U.S. Supreme Court for a writ of certiorari.
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Issue:
Does the Fourth Amendment's warrant requirement compel police to obtain a warrant to search a closed container located within a vehicle when they have probable cause to believe the container, but not the vehicle itself, contains contraband?
Opinions:
Majority - Justice Blackmun
No. The Fourth Amendment does not require a separate warrant to search a container in a vehicle when there is probable cause to search that container. The Court eliminated the distinction established in United States v. Chadwick and Arkansas v. Sanders, which required a warrant to search a container in a car if probable cause was limited to the container itself, while the rule from United States v. Ross permitted warrantless searches of containers found during a general vehicle search. The Court reasoned that this dual-rule system was confusing for law enforcement and courts, created anomalous results, and provided only minimal additional privacy protection. It is better to have one clear-cut rule: if police have probable cause to believe a container in a car holds contraband, they may search that container without a warrant, just as they could search the car itself if they had probable cause.
Concurring - Justice Scalia
No. The judgment should be reversed not because of an 'automobile exception,' but because a warrantless search of a closed container outside a private building, supported by probable cause, is inherently reasonable under the Fourth Amendment. Justice Scalia argued that the Court's 'warrant requirement' jurisprudence is riddled with so many exceptions it is unrecognizable and inconsistent. Instead of creating more complex exceptions, the Court should return to the Fourth Amendment's core principle of 'reasonableness' as understood at common law. Under that standard, this search was reasonable and did not require a warrant.
Dissenting - Justice White
Yes. Justice White joined Justice Stevens's dissent, agreeing that the judgment of the California Court of Appeal should be affirmed.
Dissenting - Justice Stevens
Yes. The Fourth Amendment should require a warrant to search the container in this situation. The majority's decision erodes the cardinal principle that warrantless searches are per se unreasonable, subject only to well-delineated exceptions. The distinction between probable cause to search a car (Ross) and probable cause to search a specific container within it (Sanders) was logical and protected a significant privacy interest in one's personal effects. A person does not lose their expectation of privacy in a briefcase or bag simply by placing it in a car. The police could have lawfully seized the bag and obtained a warrant, which strikes the proper balance between law enforcement needs and individual privacy rights.
Analysis:
This decision significantly simplified Fourth Amendment doctrine regarding vehicle searches by collapsing the distinction between the 'Ross rule' and the 'Chadwick-Sanders rule.' By overruling Arkansas v. Sanders, the Court established a single, unified standard for searching containers found in automobiles, making it easier for law enforcement to apply. The ruling broadened the automobile exception and effectively reduced the privacy protection for closed containers once they are placed inside a vehicle, as the specific location of probable cause (the car vs. the container) no longer determines whether a warrant is required.
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