Washington v. Chrisman

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 plain view. 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. Daugherty spotted 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, which uncovered three small bags of marijuana, $112 in cash, and some lysergic acid diethylamide (LSD), another controlled substance.