United States v. Rabinowitz
339 U.S. 56 (1950)
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Rule of Law:
A search incident to a lawful arrest is not unreasonable under the Fourth Amendment solely because the officers had a practical opportunity to obtain a search warrant. The relevant test is the reasonableness of the search itself, judged by the total facts and circumstances of the case.
Facts:
- A printer in government custody disclosed that he had delivered a large number of stamps with forged overprints to Rabinowitz, a stamp dealer.
- A government postal employee was sent to Rabinowitz's one-room business office and purchased four stamps which were later confirmed to have forged overprints.
- Federal officers learned that Rabinowitz had a prior conviction for a similar stamp-altering offense.
- Armed with a valid warrant for his arrest, officers went to Rabinowitz's office.
- After arresting Rabinowitz inside his office, the officers conducted an hour-and-a-half search of his desk, safe, and file cabinets.
- During the search, officers found and seized 573 stamps with forged overprints.
Procedural Posture:
- Rabinowitz was indicted on two counts in the U.S. District Court.
- Rabinowitz filed motions to suppress the 573 stamps seized during the search, which the trial court denied.
- Following a trial, a jury convicted Rabinowitz on both counts.
- Rabinowitz, as appellant, appealed to the U.S. Court of Appeals.
- The Court of Appeals reversed the conviction, holding that the search was illegal because the officers had failed to obtain a search warrant despite having ample time to do so.
- The United States, as petitioner, was granted a writ of certiorari by the U.S. Supreme Court to review the decision of the Court of Appeals.
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Issue:
Does a warrantless search of a person's entire one-room office, conducted contemporaneously with a lawful arrest of that person in the office, violate the Fourth Amendment's protection against unreasonable searches and seizures?
Opinions:
Majority - Mr. Justice Minton
No, a warrantless search of a person's one-room office, conducted contemporaneously with a lawful arrest in that office, does not violate the Fourth Amendment. The validity of a search incident to a lawful arrest depends on whether the search was reasonable, not on whether it was practicable for officers to obtain a search warrant. The Court explicitly overruled Trupiano v. United States, which had established the practicability test. Reasonableness is determined by the facts and circumstances of each case, including that the search was incident to a valid arrest, confined to a small business room under the arrestee's immediate and complete control, and targeted the instrumentalities and fruits of the crime for which the arrest was made. To require a warrant when a search is otherwise reasonable is to misread the Fourth Amendment, which forbids only 'unreasonable' searches.
Dissenting - Mr. Justice Frankfurter
Yes, a warrantless search of a person's entire office violates the Fourth Amendment when officers had ample opportunity to secure a search warrant. The Fourth Amendment's history shows its central purpose is to require judicial authorization via a warrant before a search, with exceptions permitted only out of absolute necessity. The exception for a search incident to arrest is justified only by the need to disarm the suspect and prevent the destruction of evidence, which limits the permissible search to the arrestee's person and the area within his immediate physical control. By allowing a full search of the premises, the majority makes the narrow exception swallow the constitutional rule, sanctioning the very type of general, rummaging search the Amendment was designed to prohibit, especially where, as here, officers had over a week to obtain a warrant.
Analysis:
This decision significantly expanded the permissible scope of a search incident to a lawful arrest by replacing the 'practicability' test from Trupiano with a more flexible 'total atmosphere of the case' reasonableness standard. It de-emphasized the warrant requirement, giving law enforcement greater discretion to search areas under an arrestee's control without prior judicial approval. This broader interpretation of the search-incident-to-arrest exception held for nearly two decades until it was substantially narrowed by Chimel v. California (1969), which limited such searches to the arrestee's 'wingspan' or the area within their immediate control.
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