United States v. Chadwick
433 U.S. 1 (1977)
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Rule of Law:
Once law enforcement officers have reduced personal luggage to their exclusive control, and there is no longer any danger that the arrestee might gain access to the property to seize a weapon or destroy evidence, a search of that property is no longer an incident of the arrest and requires a warrant.
Facts:
- On May 8, 1973, Amtrak officials in San Diego observed Gregory Machado and Bridget Leary loading a heavy, double-locked brown footlocker onto a train bound for Boston.
- Officials noted the footlocker was leaking talcum powder, a substance used to mask the odor of drugs, and reported their suspicions to federal agents.
- When the train arrived in Boston two days later, federal agents with a drug-sniffing dog kept Machado and Leary under surveillance as they claimed the footlocker.
- After the dog signaled the presence of a controlled substance inside the footlocker, Machado and Leary were joined by Joseph Chadwick.
- The three individuals lifted the 200-pound footlocker into the trunk of Chadwick's waiting automobile.
- While the car's trunk was still open and before the engine had been started, federal agents arrested all three individuals.
Procedural Posture:
- Respondents were indicted in the U.S. District Court for the District of Massachusetts for possession of marihuana with intent to distribute and conspiracy.
- Before trial, respondents filed a motion to suppress the marihuana obtained from the footlocker, arguing the warrantless search violated the Fourth Amendment.
- The District Court, a court of first instance, granted the motion to suppress the evidence.
- The United States (appellant) appealed the suppression order to the U.S. Court of Appeals for the First Circuit.
- A divided panel of the First Circuit, an intermediate appellate court, affirmed the District Court's decision.
- The United States (petitioner) then successfully petitioned the U.S. Supreme Court for a writ of certiorari.
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Issue:
Does the Fourth Amendment require law enforcement to obtain a search warrant before searching a locked footlocker that has been lawfully seized and is under their exclusive control, when there is probable cause to believe it contains contraband?
Opinions:
Majority - Chief Justice Burger
Yes. A warrantless search of personal luggage seized by law enforcement is unreasonable under the Fourth Amendment once the luggage is under the exclusive control of the police and no exigent circumstances exist. A person's expectation of privacy in personal luggage is substantially greater than in an automobile. Unlike cars, luggage's primary function is as a repository for personal effects, its contents are not open to public view, and it is not subject to pervasive government regulation. Because the footlocker search was remote in time and place from the arrest and the property was securely in police control, the search-incident-to-arrest exception does not apply. With no risk of the contents being lost or destroyed, agents were required to obtain a warrant from a neutral magistrate before invading the respondents' legitimate privacy interests.
Dissenting - Justice Blackmun
No. A warrant should not be required to search any movable property in the possession of a person properly arrested in a public place. This decision creates an impractical and confusing distinction between personal effects on an arrestee's person, which can be searched without a warrant, and other movable property like this footlocker. An arrest is a significant intrusion that diminishes the arrestee's expectation of privacy in their possessions. Requiring a warrant in these circumstances is a mere formality that offers little practical protection for Fourth Amendment values and creates arbitrary outcomes based on slight factual variations, such as whether the car had started moving or where exactly the arrest took place.
Concurring - Justice Brennan
Yes. The majority opinion is correct in its entirety. It is deeply distressing that the Department of Justice would advance an extreme argument suggesting the Warrant Clause primarily protects only private dwellings. Furthermore, the dissent's assumption that alternative police actions, such as searching the footlocker on the spot as incident to arrest or after the car was moving under the automobile exception, would have been constitutional is questionable. A heavy, securely locked footlocker is not obviously within an arrestee's 'immediate control' under Chimel, and it is not clear that the automobile exception extends to searching locked containers found within a vehicle.
Analysis:
United States v. Chadwick is a landmark decision that established a high expectation of privacy in personal luggage and closed containers. The ruling clarified that the 'automobile exception' to the warrant requirement is not a general 'movable property' exception and does not apply to luggage simply because it was placed in a car. By distinguishing the privacy interests in luggage from those in vehicles, the Court reinforced the principle that warrantless searches are per se unreasonable and their exceptions are narrowly construed. This case set the stage for decades of Fourth Amendment litigation over the scope of searches involving containers found both in and out of vehicles.
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