Chambers v. Maroney
399 U.S. 42 (1970)
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Rule of Law:
If police have probable cause to conduct a warrantless search of an automobile on a public roadway, they may either conduct the search immediately on the scene or seize the vehicle and search it later at the police station without obtaining a warrant.
Facts:
- On May 20, 1963, a Gulf service station in Pennsylvania was robbed at gunpoint by two men.
- The robbers took currency and coins, placing the coins into the station attendant's right-hand glove before taking it.
- Witnesses reported seeing a blue compact station wagon with four men speeding away from the area shortly after the robbery.
- The attendant and witnesses described one robber as wearing a green sweater and the other a trench coat.
- Within an hour, police stopped a matching blue compact station wagon about two miles away carrying four men.
- One occupant, petitioner Chambers, was wearing a green sweater, and a trench coat was found inside the car.
- Police arrested all the occupants and drove the station wagon to the police station.
- At the station, a thorough search of the car revealed two .38-caliber revolvers, a right-hand glove containing change, and property from another robbery.
Procedural Posture:
- Chambers was convicted of two armed robberies in a Pennsylvania state trial court, after his first trial ended in a mistrial.
- He sought a writ of habeas corpus in the state court system, but the petition was denied, and the denial was affirmed by the Pennsylvania appellate courts.
- Chambers then filed a petition for a writ of habeas corpus in the United States District Court for the Western District of Pennsylvania.
- The District Court denied the petition without holding an evidentiary hearing.
- The U.S. Court of Appeals for the Third Circuit (appellate court) affirmed the District Court's denial.
- The U.S. Supreme Court granted certiorari to review the Court of Appeals' decision.
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Issue:
Does a warrantless search of an automobile at a police station, conducted after the vehicle has been stopped on the road and its occupants arrested, violate the Fourth Amendment if the police had probable cause to search the vehicle when it was first stopped?
Opinions:
Majority - Mr. Justice White
No. A warrantless search of an automobile at a police station does not violate the Fourth Amendment if police had probable cause to search it when it was first stopped. The Court reasoned that under the automobile exception established in Carroll v. United States, a warrantless search of a movable vehicle is permissible if there is probable cause to believe it contains evidence of a crime. This justification does not vanish simply because the car has been immobilized at a police station. The Court found no constitutional difference between an immediate warrantless search on the highway and seizing the car to search it later at the station, as the probable cause factor and the car's inherent mobility remain. Seizing the car and holding it pending a warrant is at least as great an intrusion as an immediate search, making either course reasonable under the Fourth Amendment.
Concurring - Mr. Justice Stewart
Mr. Justice Stewart concurred, joining the Court's opinion and judgment. He wrote separately to reiterate his view that alleged Fourth Amendment violations should not be sufficient grounds for a collateral attack on a conviction via habeas corpus. However, bound by existing precedent, he considered the merits of the Fourth Amendment claim and agreed with the majority's conclusion.
Concurring-in-part-and-dissenting-in-part - Mr. Justice Harlan
Yes. The warrantless search at the station violates the Fourth Amendment. Justice Harlan argued that the exception to the warrant requirement is justified only by the exigent circumstances presented by a vehicle's mobility on a public way. Once the vehicle is in police custody at the station and its occupants are arrested, the exigency disappears, and there is no longer a justification for bypassing the warrant requirement. He contended that the lesser intrusion would be to seize the vehicle for the brief time necessary to obtain a warrant from a magistrate, thereby preserving Fourth Amendment protections. By allowing a search at the convenience of the police, the majority created a special rule for automobiles that is inconsistent with the general principle that warrantless searches are per se unreasonable.
Analysis:
This case significantly clarifies and arguably expands the scope of the automobile exception to the Fourth Amendment's warrant requirement. It establishes that the probable cause to search a vehicle on the scene does not dissipate once the vehicle is moved to a secure location like a police station. This holding gives law enforcement considerable flexibility, allowing them to choose between a potentially unsafe roadside search and a more thorough, safer search at the station, without the need to secure a warrant. The decision reinforces the unique constitutional status of automobiles compared to homes or offices, grounding the exception not just in the immediate exigency of mobility, but in the inherent mobility of the vehicle itself.
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