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Florida v. Wells



State of Florida


Martin Leslie Wells

Petitioner's Claim

It is not a violation of the Fourth Amendment for a police officer to open a locked suitcase that is found in the trunk of an arrestee's vehicle, even if the police station has no clear policy on the opening of locked containers during an inventory search.

Chief Lawyer for Petitioner

Michael J. Neimand

Chief Lawyer for Respondent

Huntley Johnson

Justices for the Court

Harry A. Blackmun, William J. Brennan, Jr., Anthony M. Kennedy, Thurgood Marshall, Sandra Day O'Connor, William H. Rehnquist (writing for the Court), Antonin Scalia, John Paul Stevens, Byron R. White

Justices Dissenting



Washington, D.C.

Date of Decision

18 April 1990


Absent a policy on the opening of closed containers found by police officers during an inventory search, an inventory search that involves the opening of a locked suitcase is not sufficiently regulated under the Fourth Amendment and is therefore illegal.


The Wells decision put police departments across the country on notice that they had to craft a general policy on inventory searches in addition to rules to implement the policy. At the same time, the opinion paved the way for broader police powers in vehicle inventory searches by proclaiming that police have the discretion to open whatever containers they may find during an inventory search.

Related Cases

  • South Dakota v. Opperman, 428 U.S. 364 (1976).
  • Illinois v. Lafayette, 462 U.S. 640 (1983).
  • Colorado v. Bertine, 479 U.S. 367 (1987).

Further Readings

  • West's Encyclopedia of American Law,Volume 9. St. Paul: West Group, 1998.

Additional topics

Law Library - American Law and Legal InformationNotable Trials and Court Cases - 1989 to 1994