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 person's capacity to claim the protection of the Fourth Amendment against an unreasonable search depends not on a property right in the invaded place, but on whether that person has a legitimate expectation of privacy in the area searched.
Facts:
- A police officer received a radio call about a robbery of a clothing store, which included a description of the getaway car.
- Shortly after, the officer spotted a car matching the description and, with assistance from other officers, stopped the vehicle.
- The occupants, including petitioners Rakas and King who were passengers, were ordered out of the car.
- After the occupants exited, police searched the interior of the automobile.
- The search revealed a box of rifle shells in the locked glove compartment and a sawed-off rifle under the front passenger seat.
- Neither Rakas nor King owned the automobile.
- Rakas and King did not assert ownership of the rifle or the shells that were seized.
Procedural Posture:
- Petitioners moved to suppress the seized rifle and shells in the Circuit Court of Kankakee County, Illinois, the trial court.
- The trial court denied the motion, ruling that petitioners lacked standing to object to the search.
- Following a trial, petitioners were convicted of armed robbery.
- Petitioners appealed to the Appellate Court of Illinois, Third Judicial District, an intermediate appellate court.
- The Illinois Appellate Court affirmed the trial court's ruling, holding that a mere passenger lacks standing to challenge the legality of a vehicle search.
- The Illinois Supreme Court, the state's highest court, denied petitioners' request for leave to appeal.
- The United States Supreme Court granted certiorari.
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Issue:
Does a police search of an automobile's interior violate the Fourth Amendment rights of passengers who have no property or possessory interest in the vehicle or the items seized?
Opinions:
Majority - Mr. Justice Rehnquist
No. A police search of an automobile does not violate the Fourth Amendment rights of passengers who lack a legitimate expectation of privacy in the areas searched. Fourth Amendment rights are personal and may not be vicariously asserted. The Court rejects the "legitimately on premises" standard from Jones v. United States as an overly broad measure of Fourth Amendment rights. Instead, the dispositive question, based on Katz v. United States, is whether the person challenging the search had a 'legitimate expectation of privacy' in the place searched. Here, the petitioners, as mere passengers, made no showing that they had any legitimate expectation of privacy in the glove compartment or the area under the seat of the car. These are areas in which a passenger, simply by virtue of their status as a passenger, would not normally have a legitimate expectation of privacy.
Dissenting - Mr. Justice White
Yes. The search violated the petitioners' Fourth Amendment rights because a person legitimately present in a private place, including an automobile, is protected from unreasonable governmental interference. The majority's decision improperly ties Fourth Amendment protections to property law concepts, effectively overruling the core principle of Jones v. United States. This holding declares an 'open season' on automobiles, inviting police to conduct unreasonable searches of vehicles with multiple occupants, knowing that passengers will likely be unable to challenge the search. This new rule is unworkable and undermines the deterrent effect of the exclusionary rule in a context where it is most needed.
Concurring - Mr. Justice Powell
No. The search did not violate the petitioners' Fourth Amendment rights because they had no reasonable expectation of privacy in the areas searched. The focus should be on the reasonableness of the asserted privacy expectation in light of all circumstances, not on the 'talisman of legitimate presence.' The expectation of privacy in an automobile is significantly lower than in a home. It is unrealistic to suggest that passengers in a car, who have no control over the vehicle or its locked compartments, have a reasonable expectation that those areas will remain free from a search after a lawful stop.
Analysis:
Rakas v. Illinois marks a significant doctrinal shift in Fourth Amendment law, replacing the 'legitimately on the premises' test for standing with the more subjective 'legitimate expectation of privacy' standard from Katz. This decision narrows the scope of individuals who can challenge a search, requiring a defendant to demonstrate a personal privacy interest in the specific area searched, not just their lawful presence. The ruling makes the inquiry more fact-intensive and arguably reduces Fourth Amendment protections for individuals in shared spaces like automobiles. It continues the Court's trend of defining Fourth Amendment rights as personal and non-vicarious, placing a higher burden on defendants seeking to suppress evidence.
