Carroll v. United States

The ruling in this case created the automobile exception to the general rule that searches require warrants. Evidence from warrantless automobile searches is admissible in court as long as the officer had probable cause to search.

In January of 1920 the Eighteenth Amendment went into effect, prohibiting the manufacture, sale, or transportation of intoxicating liquors. Congress passed the Volstead Act to implement the Eighteenth Amendment. The act forbade any person to manufacture, sell, barter, transport, import, export, deliver, furnish, or possess liquor. The commissioner of internal revenue enforced the act with fewer than 2,000 agents to police the entire country. Because Congress never granted enough money for more than token enforcement of the act, gangs took control of the illegal liquor trade, bootlegging, smuggling, and running speakeasies.

On 15 December 1921, Fred Cronenwett, chief prohibition officer, and other officers, saw George Carroll and John Kiro driving towards Grand Rapids, Michigan. Cronenwett recognized the occupants and the automobile and decided to follow them. After stopping the car, Cronenwett asked the occupants to get out. He searched the car and discovered 69 quarts of whisky hidden in the upholstery. He did not have a search warrant.