Coolidge v. New Hampshire
403 U.S. 443 (1971)
Rule of Law:
A search warrant is invalid if not issued by a neutral and detached magistrate. Furthermore, for a warrantless seizure to be justified under the plain view doctrine, the discovery of the evidence must be inadvertent.
Facts:
- After 14-year-old Pamela Mason was found murdered, police began investigating Edward Coolidge.
- Police questioned Coolidge at his home, where he cooperatively showed them three guns.
- While Coolidge was at the police station for a lie detector test, officers visited his wife and, with her consent, took four of his guns and some clothing.
- Several weeks later, the State Attorney General, who was personally in charge of the investigation and would serve as chief prosecutor, decided there was enough evidence to arrest Coolidge and search his two cars.
- Acting in his capacity as a justice of the peace, the Attorney General personally issued the arrest and search warrants.
- Police arrested Coolidge inside his house. His 1951 Pontiac automobile was parked in the driveway, plainly visible from the street and the house.
- About two and a half hours after the arrest, police had the car towed to the police station.
- The car was searched two days later, again a year later, and a third time after that, with vacuum sweepings from the car being used as evidence at trial.
Procedural Posture:
- Edward Coolidge filed pretrial motions in the New Hampshire state trial court to suppress evidence seized from his home and car.
- The trial judge referred the motions to the New Hampshire Supreme Court, which ruled the evidence was admissible.
- At trial, a jury convicted Coolidge of murder, and he was sentenced to life imprisonment.
- Coolidge appealed his conviction to the New Hampshire Supreme Court, which affirmed the judgment.
- The United States Supreme Court granted certiorari to review the constitutional questions raised by the admission of the evidence.
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Issue:
Does the warrantless seizure and subsequent search of an automobile parked in a suspect's driveway, conducted after the suspect has been arrested and removed from the scene, violate the Fourth Amendment when police had probable cause but also had ample opportunity to obtain a valid warrant?
Opinions:
Majority - Justice Stewart
Yes, the seizure and search of the automobile violated the Fourth Amendment. First, the warrant was unconstitutional because it was issued by the State Attorney General, who was leading the investigation and prosecution, and therefore was not a 'neutral and detached magistrate.' The search must therefore be justified by an exception to the warrant requirement, but none apply here. The 'search incident to arrest' exception fails because the car was not within Coolidge's immediate control when he was arrested inside his house, and the search was not contemporaneous with the arrest. The 'automobile exception' is inapplicable because it requires exigent circumstances, which were absent here; the car was parked on private property, immobile, and the police had secured the scene, providing ample time to obtain a valid warrant. Finally, the 'plain view' doctrine does not justify the seizure because the discovery of the car was not inadvertent; the police knew of its existence and location in advance and intended to seize it all along.
Concurring - Justice Harlan
Yes, the seizure and search were unconstitutional. While expressing a desire to overrule Mapp v. Ohio and Ker v. California, which applied federal exclusionary rules to the states, he concurs with the judgment under existing precedent. A contrary result would significantly weaken the Fourth Amendment's warrant requirement, a course contrary to the Court's recent decision in Chimel v. California. The case is close, but the need to uphold the warrant requirement tips the balance in favor of reversal.
Dissenting - Justice Black
No, the seizure and search of the automobile did not violate the Fourth Amendment. The Fourth Amendment does not contain an exclusionary rule. The warrant was valid, or any error in its issuance by the Attorney General was harmless beyond a reasonable doubt given the overwhelming probable cause. Even without a warrant, the seizure was reasonable as a search incident to a lawful arrest, under the automobile exception established in Chambers v. Maroney, and under the plain view doctrine. The majority's creation of an 'inadvertence' requirement for the plain view doctrine is a novel rule that contradicts prior holdings.
Dissenting - Justice White
No, the seizure and search of the automobile did not violate the Fourth Amendment. The car was lawfully seized as evidence of the crime in plain sight, and thereafter lawfully searched under Cooper v. California. The majority's new 'inadvertence' requirement for the plain view doctrine is an unnecessary, punitive, and extravagant application of the exclusionary rule that will accomplish nothing to further Fourth Amendment ends. The automobile exception should apply to any readily movable vehicle, regardless of whether it is currently in motion, making the distinction between a car on the highway and one in a driveway tenuous and without a basis in common sense.
Dissenting - Chief Justice Burger
No, the seizure and search of the automobile did not violate the Fourth Amendment. Joining the dissents of Justices White and Black, he finds no basis to reverse the conviction. This case illustrates the 'monstrous price' paid for the judicially created exclusionary rule.
Analysis:
This decision significantly reinforces the primacy of the Fourth Amendment's warrant requirement by narrowing three major exceptions. It establishes that the official issuing a warrant must be completely detached from the 'competitive enterprise of ferreting out crime.' Most importantly, it adds a new 'inadvertence' prong to the plain view doctrine, preventing police from contriving a 'plain view' situation to seize evidence they already expect to find. The case also clarifies that the automobile exception is founded on exigent circumstances and does not create a blanket rule for all vehicles, particularly those parked on private property when police have secured the scene.
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