Williams v. United States
1971 U.S. LEXIS 58, 401 U.S. 646, 28 L. Ed. 2d 388 (1971)
Premium Feature
Subscribe to Lexplug to listen to the Case Podcast.
Rule of Law:
A new constitutional rule of criminal procedure will not be applied retroactively if its primary purpose is to deter future unconstitutional conduct rather than to overcome a procedural flaw that substantially impairs the truth-finding function of a trial. The retroactivity of a new rule is determined by weighing its purpose, the extent of law enforcement's reliance on the old standard, and the effect retroactive application would have on the administration of justice.
Facts:
- On March 31, 1967, federal agents obtained a warrant to arrest petitioner Williams on narcotics charges.
- That same night, agents arrested Williams at his home.
- Following the arrest, eight officers conducted a search of Williams' entire house for approximately one hour and 45 minutes.
- During this search, the agents discovered and seized a quantity of heroin from a closet shelf in a bedroom.
- In a separate incident, federal agents arrested petitioner Elkanich in his apartment without a warrant on narcotics charges.
- Incident to Elkanich's arrest, multiple agents searched his four-room apartment for over an hour.
- The agents discovered and seized marked bills, previously used by an undercover agent, from a broom closet.
Procedural Posture:
- Petitioner Williams was convicted of narcotics violations in a federal district court (trial court) after the court admitted heroin seized from his home into evidence.
- Williams appealed his conviction to the U.S. Court of Appeals for the Ninth Circuit.
- The Court of Appeals affirmed the conviction, holding that the Supreme Court's intervening decision in Chimel v. California was not retroactive.
- In a separate case, petitioner Elkanich was convicted of narcotics violations in a federal district court, and his conviction was affirmed on direct appeal.
- Elkanich later filed a motion for collateral relief (under 28 U.S.C. § 2255) in the district court, which was denied.
- Elkanich appealed the denial to the Ninth Circuit, which affirmed.
- The U.S. Supreme Court granted certiorari in both cases to decide the retroactivity of the Chimel rule.
Premium Content
Subscribe to Lexplug to view the complete brief
You're viewing a preview with Rule of Law, Facts, and Procedural Posture
Issue:
Does the Fourth Amendment rule established in Chimel v. California, which limits the scope of a search incident to a lawful arrest, apply retroactively to searches conducted before the date of that decision?
Opinions:
Majority - Mr. Justice White
No. The rule announced in Chimel v. California does not apply retroactively to searches conducted prior to the date of that decision. New constitutional rules are not applied retroactively when their purpose is to deter police misconduct rather than to correct a serious flaw in the trial's truth-finding process. The exclusionary rule's purpose is to deter Fourth Amendment violations, not to question the reliability of the evidence seized; therefore, retroactivity is not required. The Court applies a three-factor analysis considering: (1) the purpose of the new rule, (2) the reliance by law enforcement on the old rule, and (3) the effect of retroactive application on the administration of justice. Here, the purpose of Chimel was deterrence, law enforcement justifiably relied on the prior, broader standards of Harris and Rabinowitz, and retroactivity would impose a severe burden on the justice system. The Court also holds that for this Fourth Amendment rule, there is no constitutional difference between cases on direct review and those on collateral attack.
Concurring - Mr. Justice Brennan
No. The rule in Chimel should only apply to searches conducted after it was decided. Applying the three-part test from Stovall v. Denno confirms this result. First, the purpose of the Chimel rule is to vindicate privacy rights and deter future misconduct, not to improve the reliability of the fact-finding process. Second, law enforcement authorities substantially and justifiably relied on the pre-Chimel standards set by Harris and Rabinowitz. Third, retroactive application would impose a significant burden on the judicial system by requiring numerous retrials, without serving to redress knowing violations of individual privacy or to protect the innocent.
Concurring-in-part-and-dissenting-in-part - Mr. Justice Marshall
No as to Elkanich on collateral review; Yes as to Williams on direct review. A new constitutional decision should be applied retroactively to all criminal cases that are not yet final at the time the decision is rendered. Therefore, petitioner Williams, whose case is on direct review, should receive the full benefit of the Chimel rule, and his conviction should be reversed. For cases on collateral review, like Elkanich's, the plurality's three-part analysis is appropriate, and under that analysis, the Chimel rule should not be applied retroactively.
Analysis:
This decision solidified the Court's analytical framework for the retroactivity of new constitutional rules in criminal procedure, emphasizing that rules aimed at deterring police conduct rather than ensuring trial accuracy are typically applied only prospectively. The plurality's position of treating direct and collateral review the same for Fourth Amendment retroactivity was a significant, albeit controversial, stance that simplified the doctrine but was later overruled in Griffith v. Kentucky (1987), which held that new rules apply to all cases pending on direct review. This case is crucial for understanding the evolution of retroactivity doctrine and the Court's balancing of finality in convictions against the enforcement of new constitutional protections.
