Maryland v. Dyson
527 U.S. 465, 1999 U.S. LEXIS 4200, 144 L. Ed. 2d 442 (1999)
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Rule of Law:
The automobile exception to the Fourth Amendment's warrant requirement permits a warrantless search of a readily mobile vehicle if police have probable cause to believe it contains contraband; no separate finding of exigency is required.
Facts:
- A reliable confidential informant told a St. Mary’s County Sheriff’s Deputy that Kevin Darnell Dyson had traveled to New York to purchase cocaine.
- The informant stated Dyson would be returning to Maryland later that day in a rented red Toyota with a specific license plate number, DDY 787.
- The deputy investigated and confirmed that the license plate belonged to a red Toyota Corolla rented to Dyson, whom police knew as a drug dealer.
- At 1 a.m. the following morning, deputies identified Dyson returning to the county driving the specified rental car.
- Deputies stopped the vehicle and conducted a search.
- The search revealed 23 grams of crack cocaine inside a duffel bag located in the vehicle's trunk.
Procedural Posture:
- Kevin Darnell Dyson was tried and convicted of conspiracy to possess cocaine with intent to distribute in a Maryland state trial court.
- Before trial, Dyson moved to suppress the cocaine evidence, but the trial court denied the motion.
- Dyson, as appellant, appealed his conviction to the Maryland Court of Special Appeals (an intermediate appellate court).
- The Court of Special Appeals reversed the trial court's judgment, holding the warrantless search was unconstitutional because there was no exigency.
- The State of Maryland's petition for a writ of certiorari to the Maryland Court of Appeals (the state's highest court) was denied.
- The State of Maryland, as petitioner, successfully petitioned the U.S. Supreme Court for a writ of certiorari.
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Issue:
Does the Fourth Amendment's automobile exception require a separate finding of exigent circumstances, in addition to probable cause, to justify a warrantless search of a vehicle?
Opinions:
Majority - Per Curiam
No. The automobile exception to the Fourth Amendment's warrant requirement has no separate exigency requirement. Citing longstanding precedent from cases like Carroll v. United States and United States v. Ross, the Court reaffirmed that a warrantless search of a vehicle is constitutional if it is based on probable cause that the vehicle contains evidence of a crime. The Court explicitly rejected the Maryland court's addition of a separate exigency requirement, stating it was 'squarely contrary' to established holdings in Ross and Pennsylvania v. Labron. Because the lower court found there was 'abundant probable cause' to believe Dyson's car contained contraband, that finding alone satisfied the automobile exception, and no further justification was needed.
Dissenting - Justice Breyer
No. While agreeing with the majority's statement of the law, the dissent argues that the Court should not have summarily reversed the lower court's decision without full briefing. The dissent's objection is procedural, not substantive. Because the respondent's counsel was not a member of the Supreme Court bar and did not file a response, the dissent believes the Court should have appointed an amicus curiae to argue the respondent's position to ensure a fair and complete consideration of the case, irrespective of the merits.
Analysis:
This per curiam opinion serves as a strong reaffirmation and clarification of the automobile exception's bright-line rule. By summarily reversing the lower court, the Supreme Court signaled that the principle is not open to reinterpretation and that adding a separate exigency requirement is a clear legal error. The decision simplifies the Fourth Amendment analysis for law enforcement, solidifying that probable cause is the sole prerequisite for a warrantless search of a mobile vehicle. This holding prevents lower courts from creating circuit-specific exceptions that would complicate an area of law the Court intended to be straightforward for officers in the field.
