Washington v. Chrisman

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 Fourth Amendment right to freedom from unreasonable search and seizure. This motion was denied and Chrisman was convicted on both counts. He appealed the case to the Washington Court of Appeals, which affirmed the legality of Daugherty's search. 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 person in 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 actions against the trade in illegal drugs, the Supreme Court took the case on certiorari and heard arguments on 3 November 1981.