Washington v. Chrisman

Petitioner
State of Washington
Respondent
Chrisman
Petitioner's Claim
That evidence seized during a warrantless search of the respondent's dormitory room was legally obtained and admissible in court.
Chief Lawyer for Petitioner
Ronald R. Carpenter
Chief Lawyer for Respondent
Robert F. Patrick
Justices for the Court
Harry A. Blackmun, Warren E. Burger (writing for the Court), Sandra Day O'Connor, Lewis F. Powell, Jr., William H. Rehnquist, John Paul Stevens
Justices Dissenting
William J. Brennan, Jr., Thurgood Marshall, Byron R. White
Place
Washington, D.C.
Date of Decision
13 January 1982
Decision
Upheld the state of Washington and overturned the verdict of the Washington Court of Appeals, holding that the warrantless search of the respondent's dormitory room did not violate his Fourth Amendment right to protection against unreasonable search and seizure, and that the evidence obtained in that searchwas legally admissible.
Significance
The ruling represents an early example of the Court's willingness to interpret the Fourth Amendment in such a way as to allow great discretion on the partof law enforcement authorities in conducting searches, particularly in casesinvolving the use of, or trafficking in, illegal substances. In Washington v. Chrisman, the Court interpreted the so-called "plain view rule" broadly and allowed police officers to presume that every arrest presents a riskto the arresting officer, thus freeing police officers from "reviewing courts' after-the-fact assessment of the particular arrest situation."
Call for Action
In the 1970s and 1980s public concern over the use of, and traffic in, illegal drugs rose to new levels. With drug use among youth at all time highs during the late 1970s, popular opinion demanded that some action be taken by authorities to curb the illegal drug trade. The Supreme Court was not immune to such public pressure, embarking on a consistent trend toward interpreting Fourth Amendment prohibitions against unreasonable search and seizure in such a way as to allow maximum freedom of action among law enforcement officers investigating drug cases.
A Bad Time for a Party
On the night of 1 January 1978 Washington State University student Carl Overdahl left his dormitory building carrying a half-gallon bottle of gin in plainview. His timing and his judgement were seriously flawed, given that his university prohibited the possession of alcohol on campus, and that his movements were being observed by Officer Daugherty of the university's police department. Daugherty immediately approached Overdahl and asked him to present his identification. When Overdahl responded that he would have to return to his dorm room to retrieve it, Daugherty informed him that he could go get it, but that Daugherty would have to accompany him. The two men then proceeded to Overdahl's room, which was located on the eleventh floor of the dormitory building. Upon reaching his room, Overdahl entered and began searching for his identification. Overdahl's roommate, respondent Chrisman, was in the room. While he waited, Daugherty stood in the room's doorway and glanced inside. Daughertyspotted what he believed to be marijuana seeds and a pipe sitting in plain view in Overdahl's room, and entered the room to confirm his suspicions. Daugherty was immediately satisfied that he had discovered illegal drugs on the premises, and informed Overdahl and Chrisman of their rights as criminal suspects under Miranda v. Arizona (1966).
Daugherty then informed the suspects that he intended to search their room, and that, although they had a right to demand that he obtain a warrant to do so, they could also voluntarily allow the search to commence forthwith. Overdahl and Chrisman elected to allow Daugherty to proceed with his search, whichuncovered three small bags of marijuana, $112 in cash, and some lysergic aciddiethylamide (LSD), another controlled substance.
Legal Proceedings
Chrisman was charged with possession of more that 40 grams of marijuana and possession of LSD, both felonies under Washington state law. He entered a pretrial motion to suppress the evidence obtained by Daugherty's warrantless search. Chrisman maintained that, since Daugherty had no reasonable suspicion that Overdahl would attempt to escape or destroy evidence while searching for his identification, his entrance into the dorm room violated Chrisman's FourthAmendment right to freedom from unreasonable search and seizure. This motionwas denied and Chrisman was convicted on both counts. He appealed the case tothe Washington Court of Appeals, which affirmed the legality of Daugherty'ssearch. Upon further appeal to the Washington State Supreme Court, however, Chrisman met with success. The state supreme court ruled that, because Daugherty's visual scanning of the dorm room was not triggered by "exigent circumstances," his spotting of the marijuana seeds represented an unreasonable search, and all evidence obtained by this spotting and subsequent searches was legally inadmissible. The ruling was not unanimous, however. Three justices maintained that it was reasonable for a police officer to keep an arrested personin sight at all times and that on this basis Daugherty was justified in looking into the room, and, having spotted illegal drugs, taking his subsequent actions. Given the implications of this case for future law enforcement actionsagainst the trade in illegal drugs, the Supreme Court took the case on certiorari and heard arguments on 3 November 1981.
The Plain View Rule
On 13 January 1982 the Supreme Court reversed the verdict of the Washington State Supreme Court, finding by a margin of 6-3 that Daugherty's search was reasonable and the evidence he obtained legally admissible. Justice Burger, writing for the majority, noted two main issues in the case.
First, the Court determined that it was reasonable under the Fourth Amendmentfor a police officer to monitor the movements of an arrested person. CitingPennsylvania v. Mimms (1977) and United States v. Robinson (1972), the Court noted that the "absence of affirmative indication that an arrested person might have a weapon available or might attempt to escape does notdiminish the arresting officer's authority to maintain custody over the arrested person." In so finding they validated Daugherty's having kept Overdahl inhis sight at all times, and thereby also validated Daugherty's having foundthe marijuana seeds and pipe under the plain view rule. This rule, established in the cases of Coolidge v. New Hampshire (1971) and Harris v. United States, (1968), states that authorities may seize evidence that is in plain view when evidence is discovered in a place where authorities have aconstitutional right to be without a warrant.
Having found Daugherty's initial search and seizure to be constitutionally valid under the Fourth Amendment, the Court turned to the issue of the other contraband found in the more thorough search agreed to by the respondent. The Court ruled, once again, that Daugherty had not violated the respondent's constitutional rights with his second search. Because he had informed the respondent and Overdahl of their rights as suspects per Miranda, and had alsoinformed them of their right to refuse an immediate search and demand a search warrant before further searching could occur, Chrisman and Overdahl's voluntary submission to a second search was constitutionally valid.
Impact
Washington v. Chrisman marks an early example of the Court's tendencythroughout the 1980s and 1990s to interpret the Fourth Amendment in such a way as to allow maximum freedom of action for law enforcement personnel investigating the use of, and trafficking in, illegal drugs. The implications of theCourt's decision are plain for law enforcement officers who now may: accompany an arrested person to a location of that person's choosing; demand to takean arrested person to some place where that person may be keeping their identification; look around for evidence in plain view at whatever location the arrested person takes them.
Related Cases

• Miranda v. Arizona, 384 U.S. 346 (1966).
  
• Katz v. United States, 389 U.S. 347 (1967).
  
• Harris v. United States, 390 U.S. 234 (1968).
  
• Coolidge v. New Hampshire, 403 U.S. 443 (1971).
  
• United States v. Robinson, 414 U.S. 218 (1973).

Increased Sentencing for Drug Offenders?
With its five- and ten-year minimum sentences, the Anti-Drug Abuse Act of 1986 is a leading example of the stiff sentencing for drug offenders that becamethe norm during the 1980s. In 1979, New York became the first state to passa law authorizing mandatory sentencing for drug offenders.
Nearly two decades later, however, New York and other states began to roll back the most stringent of their anti-drug measures. An example of the reason why is the case of Thomas Eddy, one of the first New Yorkers sentenced under the new laws in 1979. A National Merit Scholar attending the State Universityof New York at Binghamton, he was arrested for selling two ounces of cocaine.He expected to receive a few years in jail; instead, his sentence was fifteen years to life.
Not only have minor offenders such as Eddy received disproportionate punishments, but often the stiff penalties have evaded powerful drug kingpins who cantrade information for reduced sentences. Prison overcrowding and other issues--not the least of which is the fact that the mandatory sentences have not significantly reduced the rate of drug-related crimes--have led Michigan, Connecticut, Oklahoma, Arizona, and a dozen other states to reconsider their minimum-sentencing guidelines.
Sources
Marks, Alexandra. "Rolling Back Stiff Drug Sentences." Christian Science Monitor, 8 December 1998.