Illinois v. Lafayette
462 U.S. 640 (1983)
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Rule of Law:
A warrantless inventory search of an arrestee's personal effects, including closed containers, conducted at the police station as part of a routine booking procedure is a reasonable search under the Fourth Amendment. Such searches are justified by governmental interests in safety and security and do not require probable cause or a warrant.
Facts:
- On September 1, 1980, Officer Maurice Mietzner responded to a disturbance call at a movie theater in Kankakee, Illinois.
- Officer Mietzner found Lafayette involved in an altercation with the theater manager.
- Mietzner arrested Lafayette for disturbing the peace, handcuffed him, and transported him to the police station.
- Lafayette carried a purse-type shoulder bag with him to the station.
- At the station's booking room, Lafayette was ordered to empty his pockets and place his shoulder bag on the counter.
- Officer Mietzner then searched the contents of the bag as part of what he described as a standard inventory procedure.
- Inside a cigarette package within the bag, Mietzner discovered 10 amphetamine pills.
Procedural Posture:
- Lafayette was charged in an Illinois state court with violating the state's Controlled Substances Act.
- At a pretrial hearing, Lafayette moved to suppress the evidence found in his shoulder bag.
- The state trial court granted the motion to suppress the evidence.
- The State of Illinois, as appellant, appealed to the Illinois Appellate Court, an intermediate appellate court.
- The Illinois Appellate Court affirmed the trial court's suppression order, finding the search violated the Fourth Amendment.
- The Illinois Supreme Court, the state's highest court, denied the State's petition for discretionary review.
- The State of Illinois successfully petitioned the U.S. Supreme Court for a writ of certiorari.
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Issue:
Does the Fourth Amendment permit police, as part of a routine station-house booking procedure, to conduct a warrantless search of a shoulder bag belonging to a person lawfully under arrest?
Opinions:
Majority - Chief Justice Burger
Yes, the Fourth Amendment permits such a search. A warrantless inventory search of an arrestee's personal effects during booking is a reasonable administrative procedure and a well-established exception to the warrant requirement. The search is justified by a range of governmental interests, including the need to deter false claims of stolen property, inhibit theft by police, prevent arrestees from harming themselves or others with concealed weapons or contraband, and verify the arrestee's identity. The reasonableness of the search does not turn on the existence of less intrusive alternatives, such as sealing the bag, because the Fourth Amendment does not mandate that police employ the least intrusive means available. The need for a clear, standardized rule for police officers outweighs the burden of making case-by-case judgments about which containers can be searched.
Concurring - Justice Marshall
Yes, but only because it qualifies as a standard inventory search prior to incarceration. The practical necessities of securing persons and property in a jailhouse justify such a search. However, this search would not have been lawful as a search incident to arrest at the scene, because the offense of disturbing the peace has no 'fruits' or 'evidence' to be discovered, and once the bag was seized, any threat from weapons was eliminated, removing the justification for a warrantless search of its contents under that doctrine.
Analysis:
This case solidifies the 'inventory search' as a distinct and significant exception to the Fourth Amendment's warrant requirement. The Court's rejection of a 'least intrusive means' test provides law enforcement with considerable discretion in conducting administrative searches of arrestees' property during the booking process. The decision prioritizes the administrative and safety needs of police departments over an individual's privacy interest in closed containers once they are in custody and about to be incarcerated. This creates a bright-line rule that simplifies the process for officers, allowing them to search any container possessed by an arrestee without needing to analyze its specific characteristics or potential for danger.
