Michigan v. Thomas

Supreme Court of the United States
102 S. Ct. 3079, 73 L. Ed. 2d 750, 1982 U.S. LEXIS 145 (1982)

ELI5:

Rule of Law:

Under the automobile exception, if police officers have probable cause to believe a vehicle contains contraband, they may conduct a warrantless search of any part of the vehicle and its contents that may conceal the object of the search. This justification to conduct a warrantless search does not vanish once the vehicle has been immobilized and is in police custody.

Facts:

Police stopped a car for failing to signal a turn, in which Thomas was a front-seat passenger.
As officers approached, they saw Thomas bend forward so his head was below the dashboard level.
The officers observed an open bottle of malt liquor on the floorboard between Thomas's feet.
Thomas was arrested for possession of open intoxicants, and the 14-year-old driver was cited for not having a license.
Thomas claimed ownership of the car, which was subsequently impounded.
During a standard inventory search before the car was towed, an officer found two bags of marihuana in the unlocked glove compartment.
A second officer then conducted a more thorough search of the vehicle.
The second officer discovered a loaded .38-caliber revolver inside the air vents under the dashboard.

Procedural Posture:

Thomas was convicted of possession of a concealed weapon in a Michigan trial court.
Thomas moved for a new trial, arguing the revolver was seized pursuant to an illegal search; the trial court denied the motion.
Thomas, as appellant, appealed to the Michigan Court of Appeals.
The Michigan Court of Appeals reversed the conviction, holding that the warrantless search violated the Fourth Amendment.
The State of Michigan, as petitioner, sought a writ of certiorari from the Supreme Court of the United States.

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Issue:

Does the Fourth Amendment permit police officers to conduct a comprehensive, warrantless search of an automobile after it has been impounded, once the discovery of contraband during an initial search provides probable cause to believe the vehicle contains more contraband?

Opinions:

Majority - Per Curiam

Yes. The Fourth Amendment permits such a search. The discovery of contraband in the vehicle's glove compartment gave officers probable cause to believe that other contraband was present elsewhere in the automobile. Under the automobile exception established in cases like Chambers v. Maroney, the existence of probable cause justifies a warrantless search of every part of the vehicle and its contents that may conceal the object of the search. The justification for this warrantless search does not depend on a separate showing of exigent circumstances, nor does it disappear merely because the vehicle has been immobilized and secured in police custody. Therefore, the Michigan Court of Appeals erred by holding that the absence of exigent circumstances invalidated the search of the air vents.

Analysis:

This case strongly reaffirms and clarifies the scope of the automobile exception to the Fourth Amendment's warrant requirement. The decision establishes that the justification for a warrantless vehicle search is grounded in the probable cause developed at the scene, not in a continuing, case-by-case assessment of the vehicle's mobility. By detaching the search's validity from the concept of 'exigent circumstances' post-impoundment, the Court provides a bright-line rule for law enforcement. This precedent solidifies that once probable cause exists to search a vehicle, the authority to search extends to the entire vehicle and does not terminate simply because police have secured it.

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