Robbins v. California
453 U.S. 420, 1981 U.S. LEXIS 132, 69 L. Ed. 2d 744 (1981)
Premium Feature
Subscribe to Lexplug to listen to the Case Podcast.
Rule of Law:
The Fourth Amendment's protection against unreasonable searches and seizures requires police to obtain a warrant before opening any closed, opaque container found during a lawful warrantless search of an automobile, unless the container's contents are in plain view or can be inferred from its distinctive outward appearance.
Facts:
- California Highway Patrol officers stopped Richard Robbins' station wagon for erratic driving.
- Upon Robbins opening the car door to retrieve the registration, the officers smelled marihuana smoke.
- The officers searched the passenger compartment of the car and found marihuana.
- The officers then opened the station wagon's tailgate and lifted the cover of a recessed luggage compartment.
- Inside the compartment, they found a tote bag and two packages wrapped in green opaque plastic.
- The officers unwrapped the two plastic packages, discovering 15 pounds of marihuana in each.
Procedural Posture:
- Richard Robbins was charged with drug offenses in a California trial court.
- The trial court denied Robbins' pretrial motion to suppress the evidence found in the wrapped packages.
- A jury convicted Robbins.
- Robbins appealed to the California Court of Appeal, which affirmed the conviction.
- The U.S. Supreme Court granted certiorari, vacated the state court's judgment, and remanded the case for reconsideration in light of Arkansas v. Sanders.
- On remand, the California Court of Appeal again affirmed the conviction.
- The U.S. Supreme Court again granted certiorari to hear the case.
Premium Content
Subscribe to Lexplug to view the complete brief
You're viewing a preview with Rule of Law, Facts, and Procedural Posture
Issue:
Does the warrantless search and opening of a closed, opaque container discovered in the luggage compartment of an automobile during a lawful search of the vehicle violate the Fourth Amendment?
Opinions:
Plurality - Justice Stewart
Yes, the warrantless search of the closed container violates the Fourth Amendment. A closed piece of luggage or other container found in a lawfully searched car is constitutionally protected to the same extent as such a container found anywhere else. The 'automobile exception' justifies the search of the vehicle itself but does not extend to the warrantless search of closed containers within it where an expectation of privacy exists. The Fourth Amendment protects 'effects,' and once an item is placed within a closed, opaque container, it is protected regardless of the container's nature (e.g., a suitcase versus a plastic bag). A container only loses this protection if its contents can be considered in 'plain view,' meaning its distinctive configuration, transparency, or other characteristic so clearly proclaims its contents that they are obvious to an observer, which was not established by the evidence in this case.
Concurring - Justice Powell
Yes, the search was unconstitutional. The judgment is correct because the manner in which the package was carefully wrapped and sealed demonstrated a reasonable expectation of privacy. However, the plurality's bright-line rule extending warrant protection to every closed container goes too far, as it would protect insubstantial containers in which no one has a reasonable expectation of privacy. The proper inquiry should focus on whether the owner manifested a reasonable expectation of privacy in the specific container, not on a mechanical rule for all closed containers.
Dissenting - Justice Blackmun
No, the search does not violate the Fourth Amendment. The Court should adopt a clear-cut rule that a warrant is not required to seize and search any personal property found in an automobile that may itself be seized and searched without a warrant under the automobile exception established in Carroll v. United States. The plurality's new rule requiring officers to get a warrant for containers found during a lawful car search creates confusion and is impractical.
Dissenting - Justice Rehnquist
No, the search does not violate the Fourth Amendment. The automobile exception should apply to containers found within a vehicle. Furthermore, given that officers had already found marihuana in the passenger compartment and Robbins stated, 'What you are looking for is in the back,' he could have no reasonable expectation of privacy in the contents of the garbage bags. The search falls squarely within the exception noted in Arkansas v. Sanders for containers whose contents can be inferred from their outward appearance and surrounding circumstances.
Dissenting - Justice Stevens
No, the search does not violate the Fourth Amendment. This case falls within the automobile exception. When police have probable cause to believe a vehicle contains contraband, they have the authority to conduct a thorough search of the entire vehicle, including any containers that might reasonably hold the contraband. United States v. Chadwick and Arkansas v. Sanders are distinguishable because in those cases, probable cause attached to the container itself before it was placed in a car, not to the car generally.
Analysis:
This plurality opinion represents the apex of the Chadwick-Sanders doctrine, which created a strong distinction between the privacy expectations in a vehicle versus a container within that vehicle. By extending warrant protection to any 'closed, opaque container,' the decision created a confusing and difficult standard for law enforcement. This precedent proved to be short-lived, as the Court effectively overruled it just one year later in United States v. Ross (1982), which adopted the reasoning of the dissenters here, holding that the scope of a warrantless automobile search is defined by the object of the search and the places in which there is probable cause to believe it may be found, including containers.
Unlock the full brief for Robbins v. California