Dyke v. Taylor Implement Manufacturing Co.
20 L. Ed. 2d 538, 88 S. Ct. 1472, 1968 U.S. LEXIS 1632 (1968)
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Rule of Law:
Criminal contempt punishable by a maximum of 10 days in jail and a $50 fine is a 'petty offense' that does not require a jury trial under the Sixth Amendment. A warrantless search of an automobile not conducted incident to arrest, not based on probable cause, and not performed as part of a lawful impoundment violates the Fourth Amendment.
Facts:
- In the context of a labor dispute, a Tennessee court issued an injunction against inflicting harm on employees of Taylor Implement Company.
- On February 25, 1966, shots were fired from a passing car at the home of Lloyd Duckett, a nonstriking Taylor Implement employee.
- Duckett's son-in-law, Robert Wayne Ellis, who was in the yard, fired back at the car with a pistol and believed one of his shots hit the vehicle.
- Ellis reported the incident and described the car as a two-tone 1960 or 1961 Dodge.
- A deputy sheriff, Loyd Powers, was only told to look for a suspicious 'old make model car' and was not given the more specific description.
- Powers spotted a car containing Wayne Dyke, Ed McKinney, and John Blackwell, gave chase when it sped up, and had it stopped by local police.
- The three men were arrested and taken into custody inside the McMinn County jail.
- While the men were inside the jail, officers went outside to their parked car, searched it without a warrant, and found an air rifle under the front seat.
Procedural Posture:
- Wayne Dyke, Ed McKinney, and John Blackwell were tried and found guilty of criminal contempt by the Chancery Court of McMinn County, Tennessee.
- The trial court sentenced each petitioner to 10 days in jail and a $50 fine.
- Petitioners appealed their convictions to the Tennessee Supreme Court, arguing they were denied a jury trial and that evidence from an illegal search was used against them.
- The Tennessee Supreme Court affirmed the convictions of the trial court.
- The United States Supreme Court granted the petitioners' writ of certiorari to review the case.
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Issue:
Does the warrantless search of a vehicle violate the Fourth Amendment when it is conducted after the occupants have been arrested for a traffic offense and are in custody inside a courthouse, and where police lack probable cause to believe the car contains evidence of a crime?
Opinions:
Majority - Justice White
Yes, the warrantless search of the vehicle violates the Fourth Amendment. A search of a vehicle must be contemporaneous with an arrest to be considered 'incident to arrest,' and this search was too remote in time and place because the petitioners were already in custody inside the courthouse while their car was parked outside, as established in Preston v. United States. The search is not justified under the Cooper v. California exception for impounded vehicles, as there was no evidence the car was impounded or that police had a legal basis to retain it. Finally, the automobile exception established in Carroll v. United States does not apply because the police lacked probable cause to believe the vehicle contained evidence of a crime; the searching officer had only a vague description of the car and knew only that it had sped away and had a fresh bullet hole, which was insufficient to establish probable cause. The Court also held that the petitioners were not unconstitutionally denied a jury trial, because the maximum authorized punishment of 10 days in jail and a $50 fine qualifies the criminal contempt charge as a 'petty offense' not covered by the Sixth Amendment's jury trial guarantee.
Dissenting - Justice Black
The conviction should be reversed because the petitioners were unconstitutionally denied a trial by jury. The classification of offenses as 'petty' to deny a defendant a jury trial is improper, as the word 'petty' has no exact meaning. An offense punishable by 10 days in jail behind bars is not 'petty' and should require a jury trial. Because the case should be reversed on the jury trial issue, there is no need to reach the question of the warrantless search.
Concurring - Justice Harlan
I concur in the judgment of the court and agree with the majority's reasoning that the conviction must be reversed because evidence produced by an unlawful search was admitted at trial.
Analysis:
This case significantly clarifies the boundaries of warrantless automobile searches under the Fourth Amendment. It reinforces the rule from Preston that a search incident to arrest must be substantially contemporaneous with the arrest in both time and place. The decision also narrowly construes the Cooper exception, limiting searches of impounded vehicles to situations where the police have a legal duty to take custody of the car, not merely when they park it as a convenience. By finding the police lacked probable cause, the Court underscored that the Carroll automobile exception is not a blank check and requires specific, articulable facts that a crime has been committed and evidence exists in the vehicle.
