Texas v. White
96 S. Ct. 304, 46 L. Ed. 2d 209, 1975 U.S. LEXIS 98 (1975)
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Rule of Law:
If police officers have probable cause to conduct a warrantless search of a vehicle at the scene where it was stopped, they may constitutionally conduct that search later at the police station without first obtaining a warrant.
Facts:
- Amarillo police were informed by a bank that a man matching respondent White's description and driving a matching car had attempted to pass fraudulent checks.
- Ten minutes later, police were called to another bank where White was in the process of attempting to pass more fraudulent checks at a drive-in window.
- As officers directed White to park his car at the curb, an officer and a bank employee observed him attempting to "stuff" something between the seats.
- White was arrested, and one officer drove him to the station while another officer drove White's car there.
- At the station house, White refused to consent to a search of his vehicle.
- Police proceeded to search the car anyway and discovered four wrinkled checks corresponding to those from the first reported incident.
Procedural Posture:
- Respondent White was tried in a Texas state court for knowingly attempting to pass a forged instrument.
- At trial, the court admitted checks found during the station house car search into evidence over White's Fourth Amendment objection, and a jury convicted him.
- White (as appellant) appealed to the Texas Court of Criminal Appeals, the state's highest court for criminal cases.
- The Texas Court of Criminal Appeals reversed the conviction, holding that the evidence was obtained through an unconstitutional warrantless search.
- The State of Texas (as petitioner) petitioned the U.S. Supreme Court for a writ of certiorari.
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Issue:
Does a warrantless search of an automobile at a police station violate the Fourth Amendment if police had probable cause to search the vehicle at the scene of the arrest?
Opinions:
Majority - Per Curiam
No. A warrantless search of an automobile at a police station does not violate the Fourth Amendment if police had probable cause to search the vehicle at the scene of the arrest. Relying on its precedent in Chambers v. Maroney, the Court reasoned that the justification for a warrantless search under the automobile exception does not vanish once the car is moved from the scene to the station. The Court stated, "[t]he probable-cause factor that developed at the scene still obtained at the station house." Because the trial judge found that probable cause to search the car existed, the subsequent search at the station was constitutionally permissible.
Dissenting - Marshall, J.
Yes. The warrantless station house search violated the Fourth Amendment because the police lacked an independent justification for seizing the vehicle and moving it from the scene of the arrest. The majority misinterprets Chambers v. Maroney, which permitted a station house search only because it was reasonable to move the vehicle in the first place due to the impracticality and danger of a nighttime search. In this case, the arrest occurred at 1:30 p.m. with no exigent circumstances, making the seizure and removal of the car a separate, unreasonable intrusion under the Fourth Amendment that rendered the subsequent search unlawful.
Analysis:
This decision reinforces and arguably expands the automobile exception to the Fourth Amendment's warrant requirement. By detaching the warrantless station house search from the specific exigencies that justified moving the car in Chambers v. Maroney, the Court created a more permissive, bright-line rule for law enforcement. The ruling gives officers the discretion to conduct a search at the scene or to impound the vehicle and search it later, so long as probable cause was established at the scene. This reduces the analytical burden on courts and officers by not requiring a separate justification for the vehicle's removal, but critics argue it untethers the exception from its original rationale of exigency.
