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Washington v. Chrisman

Supreme Court of United States
455 U.S. 1 (1982) (1982)
ELI5:

Rule of Law:

It is not unreasonable under the Fourth Amendment for a police officer, as a matter of routine, to monitor the movements of an arrested person and accompany them into their residence, and subsequently seize any contraband discovered in plain view.


Facts:

  • On January 21, 1978, Officer Daugherty, a university police officer, observed student Carl Overdahl carrying a bottle of gin, appearing to be under the legal drinking age.
  • Officer Daugherty stopped Overdahl, who stated his identification was in his dormitory room.
  • Overdahl asked to retrieve his ID, and Officer Daugherty stated he would have to accompany him, to which Overdahl replied 'OK.'
  • Overdahl's roommate, Chrisman, was in the room when they arrived.
  • From his position in the open doorway, Officer Daugherty observed what he believed to be marijuana seeds and a pipe used for smoking marijuana on a desk inside the room.
  • The officer entered the room to examine the items, confirming they were contraband.
  • After being read his rights, Chrisman handed the officer a box containing more marijuana, and both students then consented in writing to a full search of the room.
  • The subsequent search yielded more marijuana and LSD.

Procedural Posture:

  • Chrisman was charged in a Washington state trial court with two felony counts of possessing controlled substances.
  • The trial court denied Chrisman's pretrial motion to suppress the evidence seized from the room.
  • After a trial, Chrisman was convicted on both counts.
  • Chrisman, as appellant, appealed to the Washington Court of Appeals, which affirmed the trial court's convictions.
  • Chrisman, as appellant, then appealed to the Supreme Court of Washington.
  • The Supreme Court of Washington reversed the convictions, holding that the officer's initial entry was unlawful and the evidence should have been suppressed.
  • The State of Washington, as petitioner, successfully petitioned the U.S. Supreme Court for a writ of certiorari.

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Issue:

Does a police officer violate the Fourth Amendment by accompanying a lawfully arrested person into their residence and seizing contraband discovered there in plain view?


Opinions:

Majority - Chief Justice Burger

No, the officer's actions do not violate the Fourth Amendment. An arresting officer has a compelling interest in maintaining custody over an arrestee, which justifies monitoring their movements as a routine matter to ensure officer safety, prevent escape, and preserve evidence. This authority allows the officer to accompany the arrestee into their residence. Because the officer had a lawful right to be in the position from which he viewed the contraband, the subsequent entry and seizure were permissible under the plain view doctrine. The officer's brief hesitation in the doorway does not negate his authority to enter and maintain control over the arrestee and the situation.


Dissenting - Justice White

Yes, the officer's actions did violate the Fourth Amendment. The plain view doctrine does not, by itself, authorize a warrantless entry into a home; it only applies when an officer is already lawfully present at the place of seizure. The officer's uncontradicted testimony was that he entered the room solely to confirm his suspicion about the contraband, not for safety or to maintain control over the arrestee. Without a showing of exigent circumstances or a need to enter for custodial purposes, merely seeing contraband from the doorway does not justify a warrantless intrusion into the privacy of a home.



Analysis:

This decision establishes a significant, officer-friendly, bright-line rule that expands the scope of police authority incident to a lawful arrest. It eliminates the need for a case-by-case analysis of whether 'exigent circumstances' justify an officer accompanying an arrestee into a private dwelling. By prioritizing officer safety and custodial control, the Court created a de facto exception to the warrant requirement in these situations, making it easier for officers to conduct plain view seizures inside a home during the course of an arrest. This precedent solidifies the principle that an individual's privacy interests are diminished upon being lawfully arrested.

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