Washington v. Chrisman

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 Amendment for a police officer to monitor the movements of an arrested person. Citing Pennsylvania 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 not diminish the arresting officer's authority to maintain custody over the arrested person." In so finding they validated Daugherty's having kept Overdahl in his sight at all times, and thereby also validated Daugherty's having found the 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 a constitutional 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 also informed 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.