Carroll v. United States
Warrantless Automobile Searches Valid
Chief Justice Taft, formerly president of the United States, wrote the opinion for the majority in this case. He noted that the Stanley Amendment called for the punishment of any officer who searches a private dwelling without a warrant or who searches any other building or property where the search without a warrant is done maliciously and without probable cause. "In other words, it left the way open for searching an automobile or vehicle of transportation without a warrant, if the search was not malicious or without probable cause." Taft stated that Congress intended to make a distinction between the necessity for a search warrant for private dwellings and for automobiles, in the enforcement of the Prohibition Act. Taft believed that this distinction was consistent with the Fourth Amendment because the amendment does not denounce all searches or seizures, but only unreasonable ones. " . . . If the search and seizure without a warrant are made upon probable cause, that is, upon a belief, reasonably arising out of circumstances known to the seizing officer, that an automobile or other vehicle contains that which by law is subject to seizure and destruction, the search and seizure are valid." Taft stated that the Fourth Amendment should be understood in light of what was considered an unreasonable search and seizure when the amendment was adopted. It should be construed in a manner which conserves public interests as well as the interests and rights of individuals. Almost since the beginning of our government, the Fourth Amendment guarantee of freedom from unreasonable search and seizure has recognized a necessary difference between the search of a building and the search of a method of transportation, where it is not practical to get a warrant because the vehicle can be moved quickly.
Taft noted that people have the right to freely use the highways unless an official has probable cause to believe that a vehicle is carrying illegal goods. The apellants argued that common law states that a police officer may arrest without a warrant a person that the officer believes upon reasonable cause to have committed a felony. The officer may only arrest without a warrant if the person is guilty of a misdemeanor committed in the officer's presence. The apellants argued that since a misdemeanor must be committed in the officer's presence to justify arrest without a warrant, unless the officer can detect with his senses that the liquor was being transported, the offense was not committed in his presence. Taft felt this distinction was unsatisfactory since the main object is to forfeit and suppress the liquor. The arrest of the individual is only incidental.
The appellants based one argument on Weeks v. United States (1914), asserting that when someone is legally arrested for an offense, whatever is found upon his person or in his control that it is unlawful for him to have and which may be used to prove the offense may be seized and held as evidence in the prosecution. The appellants argued that the seizure in this case can only be justified if it were based on a valid arrest, without a seizure. Taft countered that "the right to search and the validity of the seizure are not dependent on the right to arrest. They are dependent on the reasonable cause the seizing officer has for belief that the contents of the automobile offend against the law." The nature of the offense for which, after the liquor is found and seized, the driver can be prosecuted does not affect the validity of the seizure. Taft felt that this conclusion satisfied the Fourth Amendment.
Taft next discussed the question of probable cause in this case. The prohibition agents were engaged in a regular patrol of the highways from Detroit to Grand Rapids, Detroit being one of the most active centers for smuggling liquor into the country. Their patrol involved stopping cars and seizing liquor carried in them. The officers "knew or had convincing evidence" that the "Carroll boys" were bootleggers in Grand Rapids. The officers recognized the car driven by the suspects because it was the same car they had been in when they tried to furnish whisky to the officers. The car was heading from Detroit, a major source of whisky, to Grand Rapids, where the men plied their trade. "That the officers, when they saw the defendants, believed that they were carrying liquor, we can have no doubt, and we think it is equally clear that they had reasonable cause for thinking so." The defendants had argued that the officers were not looking for the defendants when they spotted them. Taft felt this argument had no weight. When the defendants did appear, "the officers were entitled to use their reasoning faculties upon all the facts of which they had previous knowledge in respect to the defendants." The officers in this case were justified in their search and seizure because a man of reasonable caution and with their knowledge would have believed that liquor was being transported in the automobile.
- Carroll v. United States - What Becomes Of The Fourth And Fifth Amendments?
- Carroll v. United States - Significance
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