California v. Acevedo

The Supreme Court ruled in a 6-3 decision that the search of the bag in Acevedo's trunk was constitutional. Therefore, the marijuana found in the trunk was admissible as evidence at trial. In reaching this result, the Court rejected the respondent's argument that the police should have obtained a search warrant before opening the bag.

The basis of the responden'st challenge was the Fourth Amendment's prohibition of unreasonable searches and seizures. That prohibition has been repeatedly interpreted to require that authorities have "probable cause" to conduct a search, just as in an earlier case, United States v. Ross (1982). It has also been interpreted to require that in many circumstances police obtain a search warrant prior to conducting a search. Where authorities have conducted an unconstitutional search, the remedy courts have imposed is to exclude evidence obtained from the illegal search from consideration by the judge or jury at trial.

The Supreme Court initially narrowed the issues in Acevedo by refusing to review the California Courts' finding that there was probable cause to search the bag. The Supreme Court also did not question the propriety of seizing the bag. Instead, the Court focused exclusively on whether the police should have obtained a search warrant before opening the bag. The legal question addressed was, under what circumstances can a container seized from a vehicle can be searched without first obtaining a search warrant.

The answer to this question was complicated by the existence of different rules for searching vehicles and containers such as bags or suitcases. In cases involving vehicles, the police were allowed to stop a car and conduct a search of the car without first obtaining a search warrant so long as there was probable cause to believe the vehicle contained evidence or an illegal substance. That search could include searching containers found in the vehicle. In contrast, police having probable cause to believe that a container contained evidence or an illegal substance could seize the container, but could not search it without a search warrant. This distinction resulted in confusion in cases involving containers found inside vehicles. More specifically, the Court had to consider whether the rules applied to searches of vehicles or containers.

Previously, in Arkansas v. Sanders (1979), the Supreme Court had applied the container rule requiring a warrant where police had probable cause to search a container which had been placed in a car, but lacked probable cause to search the entire auto. The California Court of Appeals followed Sanders and applied the container rule to Acevedo's case. The California court concluded that the container rule applied because at the time Acevedo was stopped there was no reason to be suspicious of anything in the car other than the bag itself. Therefore, there was no cause to search the entire automobile, and the California court held the warrantless search invalid.

The Supreme Court rejected the distinction between vehicle searches and searches of containers in vehicles. It emphasized that the result was confusion for courts and police officers trying to decide whether a warrant was necessary in a particular case. The Court simplified the area by announcing one rule governing all searches of containers in vehicles:

Until today, this Court has drawn a curious line between the search of an automobile that coincidentally turns up a container and the search of a container that coincidentally turns up an automobile. The protections of the Fourth Amendment must not turn on such coincidences . . . We therefore . . . [provide] one rule to govern all automobile searches. The police may search an automobile and the containers within it where they have probable cause to believe contraband or evidence is contained.

Justice Scalia wrote a separate opinion in which he concurred with the majority. He would have gone even further in permitting warrantless searches. In his opinion a warrantless search of a closed container located outside a private building would be permissible so long as the police had probable cause to believe the article contained an illegal substance.