Florida v. Jimeno
500 U.S. 248 (1991)
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Rule of Law:
A criminal suspect's Fourth Amendment right against unreasonable searches is not violated when they consent to a vehicle search and an officer opens a closed container that could reasonably hold the object of the search. The scope of a consensual search is measured by objective reasonableness, meaning what a typical person would have understood from the exchange between the officer and the suspect.
Facts:
- Dade County police officer Frank Trujillo overheard Enio Jimeno arranging what sounded like a drug transaction on a public telephone.
- Officer Trujillo followed Jimeno's car and observed him making a right turn at a red light without stopping.
- Trujillo initiated a traffic stop and informed Jimeno he had reason to believe there were narcotics in the car.
- Trujillo asked for permission to search the car, explaining that Jimeno did not have to consent.
- Jimeno stated he had nothing to hide and gave the officer permission to search the automobile, without placing any explicit limitations on the search.
- During the search, Officer Trujillo found a folded, brown paper bag on the passenger-side floorboard.
- The officer picked up the bag, opened it, and discovered a kilogram of cocaine inside.
Procedural Posture:
- Enio Jimeno and Luz Jimeno were charged with possession with intent to distribute cocaine in a Florida trial court.
- Before trial, the Jimenos filed a motion to suppress the cocaine, arguing the search of the bag exceeded the scope of consent.
- The trial court granted the motion to suppress the evidence.
- The State of Florida appealed to the Florida District Court of Appeal, which affirmed the trial court's decision.
- The State then appealed to the Supreme Court of Florida, which also affirmed the decision to suppress the evidence.
- The State of Florida petitioned the U.S. Supreme Court for a writ of certiorari, which was granted.
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Issue:
Does a suspect's general consent to a search of their vehicle for narcotics extend to a closed but unlocked paper bag found inside the vehicle that could reasonably contain narcotics, thereby making the search of the bag permissible under the Fourth Amendment?
Opinions:
Majority - Chief Justice Rehnquist
Yes, a suspect's general consent to a vehicle search for narcotics extends to closed containers within the car that could reasonably hold the object of the search. The standard for measuring the scope of consent under the Fourth Amendment is objective reasonableness, based on what a typical, reasonable person would have understood from the exchange. Here, Officer Trujillo informed Jimeno that he was looking for narcotics. Since a reasonable person would expect narcotics to be carried in a container, Jimeno's general consent to search the car was reasonably understood to include permission to search the paper bag. Unlike a locked briefcase, which might imply a higher expectation of privacy and require more specific consent to open, an unlocked paper bag falls within the scope of a general consent to search for drugs. A suspect is free to limit the scope of their consent, but if they do not, the Fourth Amendment does not require an officer to seek separate permission for every container.
Dissenting - Justice Marshall
No, a suspect's general consent to a search of their vehicle does not extend to closed containers within it, and opening the bag violated the Fourth Amendment. An individual has a heightened and distinct expectation of privacy in a closed container compared to the interior of a car. Consenting to a search of the car's interior does not automatically merge these two separate privacy interests. A general consent is, at best, ambiguous regarding containers, and police should be required to obtain additional, specific consent to search them. The majority's reasoning—that it's reasonable because drugs are carried in containers—is flawed and could be used to justify far more intrusive searches. This ruling encourages police to exploit a citizen's ignorance rather than ensuring a knowing and intelligent waiver of constitutional rights.
Analysis:
This decision clarifies the 'objective reasonableness' standard for determining the scope of consensual searches, particularly in the context of vehicles. It establishes that a general grant of consent to search for a specific item (e.g., narcotics) implicitly authorizes the search of any containers within the area that could plausibly contain that item. The ruling places the burden on the consenting individual to explicitly limit the scope of the search if they wish to protect certain containers, rather than requiring law enforcement to request permission for each container they encounter. This strengthens the position of law enforcement in conducting consent-based searches by allowing them to interpret general consent broadly, as long as their actions are objectively reasonable based on the stated purpose of the search.
