United States v. Robinson
414 U.S. 218 (1973)
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Rule of Law:
When a police officer makes a lawful custodial arrest, a full search of the person is a reasonable search under the Fourth Amendment and requires no additional justification beyond the arrest itself.
Facts:
- On April 23, 1968, Officer Richard Jenks observed Willie Robinson driving a 1965 Cadillac.
- Based on a records check four days prior, Jenks had reason to believe Robinson was operating the vehicle with a revoked driver's permit, a criminal offense in the District of Columbia.
- Jenks initiated a traffic stop, and Robinson pulled his car over.
- After confirming Robinson's identity, Jenks informed Robinson he was under arrest for operating a motor vehicle after revocation.
- Jenks then began a pat-down search of Robinson in accordance with standard police procedure for a full-custody arrest.
- During the pat-down, Jenks felt an object in the left breast pocket of Robinson's coat but could not identify it by touch.
- Jenks reached into the pocket and retrieved a crumpled cigarette package.
- Jenks opened the package and discovered 14 gelatin capsules containing what was later confirmed to be heroin.
Procedural Posture:
- Robinson was convicted of heroin possession in the U.S. District Court for the District of Columbia (trial court).
- Robinson appealed to the U.S. Court of Appeals for the D.C. Circuit (intermediate appellate court), which remanded the case for an evidentiary hearing.
- Following the hearing, the District Court made findings adverse to Robinson.
- Robinson, as appellant, again appealed to the D.C. Circuit, which, sitting en banc, reversed his conviction, holding the heroin was obtained through an unconstitutional search.
- 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 full search of a person, conducted incident to a lawful custodial arrest for a traffic violation, violate the Fourth Amendment's protection against unreasonable searches and seizures?
Opinions:
Majority - Justice Rehnquist
No, a full search of a person incident to a lawful custodial arrest does not violate the Fourth Amendment. The authority to conduct such a search is a well-established exception to the warrant requirement, based on the need to disarm the suspect and preserve evidence. Unlike a limited 'frisk' for weapons during an investigative stop under Terry v. Ohio, a full search is justified by the fact of the custodial arrest itself, which is a significant intrusion on privacy. The Court held that this authority is not dependent on a case-by-case analysis of whether the officer subjectively feared for their safety or expected to find evidence of the particular crime for which the arrest was made. Therefore, a lawful custodial arrest establishes the authority for a full search of the person, which is a 'reasonable' search under the Fourth Amendment.
Dissenting - Justice Marshall
Yes, this search violated the Fourth Amendment. The reasonableness of every search must be evaluated on its own facts and circumstances, and its scope must be limited by its justifications. For a traffic offense where there is no evidence to be found, the only justification for a search is officer safety. Therefore, the search should be limited to a protective pat-down for weapons, as permitted in Terry v. Ohio. Once Officer Jenks removed the cigarette package from Robinson's pocket, any threat from a weapon inside it was eliminated. Opening the package was a further intrusion into Robinson's privacy that served no legitimate protective purpose and was therefore unreasonable under the Fourth Amendment. The majority's bright-line rule abandons the traditional case-by-case analysis and creates a risk of pretextual arrests made solely to conduct searches.
Concurring - Justice Powell
No, the search did not violate the Fourth Amendment. A lawful custodial arrest is a significant intrusion of state power that subordinates an individual's privacy interests. Once a person is lawfully arrested, they retain no significant Fourth Amendment interest in the privacy of their person. Therefore, the arrest itself provides the justification for a full search, and law enforcement should not be frustrated by requiring an independent justification, such as the need to find weapons or evidence.
Analysis:
This decision establishes a significant bright-line rule that simplifies the 'search incident to arrest' doctrine for law enforcement. It removes the need for officers to make on-the-spot judgments about the potential dangerousness of an arrestee or the likelihood of finding evidence related to the specific crime of arrest. By holding that the custodial arrest itself justifies a full search, the Court prioritized police safety and efficiency over a more nuanced, case-by-case analysis of reasonableness. The ruling solidifies a broad grant of authority to police and departs from the principle that the scope of a search must be strictly tied to its justification, raising concerns about the potential for pretextual traffic arrests to conduct searches for which probable cause is otherwise lacking.
