Rakas v. Illinois
99 S. Ct. 421, 58 L. Ed. 2d 387, 1978 U.S. LEXIS 2452 (1979)
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Rule of Law:
A defendant's capacity to claim Fourth Amendment protection against an unreasonable search depends not on a property right in the invaded place, but on whether the person has a legitimate expectation of privacy in that place. Mere legitimate presence on the premises is insufficient to establish a Fourth Amendment violation.
Facts:
- A police officer received a radio call about a clothing store robbery and a description of the getaway car.
- Shortly after, the officer spotted a car matching the description and began following it.
- With assistance from other officers, the police stopped the vehicle.
- The occupants of the car included the driver, who owned the car, and the petitioners, who were passengers.
- Police ordered all occupants out of the vehicle.
- After the occupants exited, officers searched the interior of the car.
- The search revealed a box of rifle shells in the locked glove compartment and a sawed-off rifle under the front passenger seat.
- The petitioners never asserted ownership of the car, the rifle, or the shells.
Procedural Posture:
- Petitioners filed a pretrial motion to suppress the seized rifle and shells in the Circuit Court of Kankakee County, Illinois (the trial court of first instance).
- The trial court denied the motion to suppress, ruling that petitioners lacked standing to object to the search of the vehicle.
- Following their convictions for armed robbery, petitioners appealed to the Appellate Court of Illinois, Third Judicial District (the intermediate appellate court).
- The Illinois Appellate Court affirmed the trial court's ruling, holding that a mere passenger without a proprietary interest in an automobile lacks standing to challenge its search.
- The Illinois Supreme Court (the state's highest court) denied petitioners leave to appeal.
- The United States Supreme Court granted certiorari to review the judgment of the Illinois Appellate Court.
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Issue:
Does a police search of an automobile, in which the defendants were merely passengers who did not own the vehicle or the property seized, violate the defendants' personal Fourth Amendment rights?
Opinions:
Majority - Justice Rehnquist
No. The police search of an automobile does not violate the personal Fourth Amendment rights of passengers who do not own the vehicle or the seized property because they do not have a legitimate expectation of privacy in the areas searched. Fourth Amendment rights are personal and may not be asserted vicariously. The Court rejected the petitioners' 'target theory,' which would have granted standing to anyone against whom a search was directed. Instead, the Court reframed the inquiry away from 'standing' and toward the substantive question of whether the challenged search infringed upon the defendant's own Fourth Amendment rights. The Court held that the 'legitimately on premises' test from Jones v. United States was too broad and formally adopted the 'legitimate expectation of privacy' standard from Katz v. United States. Applying this standard, the Court concluded that the petitioners, as mere passengers, had no legitimate expectation of privacy in the glove compartment or the area under the seat of a car they did not own.
Dissenting - Justice White
Yes. The police search of an automobile violates the Fourth Amendment rights of passengers who are legitimately present in the vehicle, as they have a reasonable expectation of privacy protected from unreasonable government intrusion. The majority's holding improperly ties Fourth Amendment protections to property law concepts, effectively protecting property instead of people. The established rule from Jones—that anyone legitimately on the premises can challenge a search—is a sound principle that should apply to automobiles. By discarding this rule, the Court's decision declares an 'open season' on automobiles, inviting police to conduct unreasonable searches of cars with multiple occupants, knowing that only the owner will have standing to object. This creates an unworkable rule and undermines the deterrent effect of the exclusionary rule where it is most needed.
Concurring - Justice Powell
No. The search did not violate the petitioners' Fourth Amendment rights because they lacked a reasonable expectation of privacy in the searched areas of the car, which is the proper standard, not mere legitimate presence. The core inquiry under Katz v. United States is whether a person's claim to privacy is reasonable in light of all the circumstances. The expectation of privacy in an automobile is significantly lower than in a home. In this case, the petitioners were passengers with no control over the vehicle or its locked compartments. Therefore, it is unrealistic to suggest they had any reasonable expectation that the glove compartment or area under the seat would be free from a search after a lawful stop.
Analysis:
This case marked a pivotal shift in Fourth Amendment jurisprudence by formally replacing the broad 'legitimately on the premises' test for standing with the more stringent 'legitimate expectation of privacy' inquiry. By subsuming the question of standing into substantive Fourth Amendment law, the Court narrowed the class of individuals who could challenge a search. This decision makes it significantly more difficult for defendants, such as guests or passengers, who lack a possessory or property interest in the place searched to suppress evidence, thereby strengthening the principle that Fourth Amendment rights are personal and cannot be vicariously asserted.
