United States v. Place - Impact

Although the Court held the Place should not be prosecuted, the Court's analysis favored the government. The decision allowed police officers to seize a person's luggage based on the police officer's reasonable suspicion that the luggage contains evidence of a crime. Prior to the Place decision, police officers had to have probable cause to believe that the luggage contained evidence of a crime before seizing it. Furthermore, under the Place decision, once the luggage is seized, a police officer may examine the luggage, without opening it, to detect the presence of contraband. Police officers may use various methods and technology to determine the content of the luggage without actually opening the luggage. If they subsequently develop probable cause to believe that the luggage contains contraband or evidence of a crime and some extraordinary circumstance exists that requires the police to act on the spot, they may search inside the luggage without obtaining a search warrant.