Trupiano v. United States
92 L. Ed. 2d 1663, 1948 U.S. LEXIS 1986, 334 U.S. 699 (1948)
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Rule of Law:
Law enforcement agents must secure and use search warrants wherever reasonably practicable; a lawful arrest does not justify a warrantless seizure of contraband when there was ample time and opportunity beforehand to obtain a warrant.
Facts:
- Farm owner Kell suspected that petitioners, including Trupiano and Antoniole, intended to build and operate an illegal distillery on his property and reported this to the federal Alcohol Tax Unit.
- Federal agents instructed Kell to allow the petitioners to rent the property, and they placed an undercover agent, Nilsen, on the farm disguised as a farmhand.
- For several months, Nilsen assisted petitioners in constructing and operating the still, all while continuously reporting detailed information about the illegal operation to his superiors.
- Nilsen provided his fellow agents with samples of the illegally produced alcohol and other items from the still premises weeks before the raid.
- On the night of the raid, after being alerted by Nilsen via radio, federal agents entered the farm with Kell's consent.
- Through an open doorway of the building housing the still, an agent observed petitioner Antoniole actively operating the distillery equipment.
Procedural Posture:
- Petitioners filed a pre-indictment motion in the U.S. District Court for the District of New Jersey to suppress the seized property and have it returned.
- The District Court, a court of first instance, denied the motion, holding that the seizure was reasonable.
- Petitioners appealed the District Court's order to the U.S. Circuit Court of Appeals for the Third Circuit.
- The Circuit Court of Appeals, an intermediate appellate court, affirmed the District Court's ruling in a per curiam order.
- The Supreme Court of the United States granted certiorari to review the judgment of the Circuit Court of Appeals.
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Issue:
Does the warrantless seizure of contraband, made during a lawful arrest, violate the Fourth Amendment when federal agents had sufficient information and opportunity to obtain a search warrant beforehand?
Opinions:
Majority - Mr. Justice Murphy
Yes, the warrantless seizure of contraband violates the Fourth Amendment under these circumstances. It is a cardinal rule that law enforcement must secure and use search warrants wherever reasonably practicable. Although the arrest of Antoniole was lawful because he was committing a felony in the discernible presence of an agent, this lawful arrest does not excuse the failure to obtain a search warrant for the contraband. The agents had known the precise location and nature of the illegal distillery for weeks and had abundant time to secure a warrant. The seizure was a planned, foreseeable event, not an unexpected discovery incident to arrest. The proximity of the contraband to Antoniole at the moment of his arrest was a fortuitous circumstance that cannot legalize a seizure for which a warrant was essential and easily obtainable. The exception for searches incident to arrest must be strictly limited to the inherent necessities of the situation, and it cannot be used to swallow the general principle that judicial sanction is required for searches and seizures.
Dissenting - Mr. Chief Justice Vinson
No, the seizure did not violate the Fourth Amendment. Federal officers made a lawful entry onto the premises, executed a valid arrest of a person committing a felony in their presence, and seized contraband that was in plain view. The long-standing rule, recognized in cases like Agnello v. United States, is that officers have the right to contemporaneously search the place where a lawful arrest is made and seize items connected with the crime. The seizure was not preceded by an exploratory search; the objects were in open view. To require a search warrant in a situation where its issuance would add nothing to the protection of Fourth Amendment rights serves only to hinder effective law enforcement. The majority's reliance on the 'fortuitous' nature of the arrestee's location creates an impractical and confusing rule that disrupts the established search-incident-to-arrest doctrine.
Analysis:
This decision significantly heightened the Fourth Amendment's warrant requirement by narrowing the scope of the search incident to a lawful arrest exception. It established that the mere practicability of obtaining a warrant is the controlling factor, even when contraband is in plain view at the scene of a valid arrest. This creates a strong preference for judicial oversight and limits police discretion in planned raids where the objects of the seizure are known in advance. The Trupiano rule, however, proved controversial and was later limited by United States v. Rabinowitz, reflecting the Supreme Court's ongoing struggle to balance individual privacy against law enforcement needs in the context of warrantless searches.
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