California v. Acevedo

Established that police need not obtain a search warrant prior to searching a closed container seized from a vehicle so long as they have probable cause to believe that the vehicle or container contains evidence or an illegal substance.

The United States' "War on Drugs" became a major concern in the 1970s and 1980s. As drug arrests increased, a growing number of defendants sought to exclude drugs found in their possession from evidence at trial. Convictions often depended upon the introduction of such evidence. In other criminal cases, defendants sought to exclude from evidence weapons that had been seized in police searches. In Acevedo the Supreme Court delineated the circumstances under which evidence seized from a vehicle would be admissible at trial.

The case arose when police officers saw Acevedo place a brown paper bag in the trunk of his car and drive away. The bag appeared to be one of a number of packages of marijuana, which police had observed being brought into the building from which Acevedo was leaving. The police stopped the car, opened the trunk and bag, and found the marijuana. Acevedo was charged with possession of marijuana for sale.

Prior to trial, Acevedo moved to exclude the marijuana from evidence. His attorney argued that the search of the bag was unconstitutional because the police did not first obtain a search warrant. The trial court denied his motion to exclude the evidence, but the California Court of Appeals reversed and ruled that the officers should not have searched the bag without obtaining a warrant. The California Supreme Court denied the state's petition for review of the court of appeals decision, following which the state applied for and was granted a review of the decision by the U.S. Supreme Court.