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United States v. Robinson

Significance

In United States v. Robinson the Court reaffirmed its views that a suspect under valid arrest may be subjected to a full search of his person, without a search warrant, and that a search incident to arrest is reasonable under the Fourth Amendment. The Court also reaffirmed that evidence found during such a search should not be excluded from court.

On 23 April 1968, Officer Richard Jenks of the District of Columbia Metropolitan Police Department saw Willie Robinson driving a 1965 Cadillac. Because of a previous investigation four days earlier, Jenks believed that Robinson was driving a car after his driver's license had been revoked. Jenks pulled Robinson over and all three occupants got out of the car. Jenks arrested Robinson for "operating after revocation and obtaining a permit by misrepresentation." Jenks searched Robinson in accordance with police department rules. During the patdown, Jenks felt something in the left breast pocket of Robinson's coat but could not tell what it was. He then reached into the pocket and pulled out a crumpled cigarette package. Jenks felt objects in the package, but did not know what they were. Upon opening the package, Jenks found 14 gelatin capsules of white powder, which turned out to be heroin. This heroin was used as evidence in a district court trial, in which Robinson was convicted of a drug offense.

The court of appeals reversed this conviction on the ground that the heroin had been found during a search that violated the Fourth Amendment, which prohibits unreasonable searches and seizures and requires a search warrant. The Supreme Court ruled that even after a police officer lawfully places a suspect under arrest for the purpose of taking him into custody, he may not ordinarily proceed to fully search the prisoner. Instead, he must make a limited frisk of the outer clothing and remove any weapons found. This decision was based on Terry v. Ohio (1968), a decision that frisking for weapons is a reasonable search even without a warrant or probable cause.

In the instant case, because this was a traffic stop, no further evidence of the crime could be obtained in a search of the arrestee. Thus, only a search for weapons could be justified. The court of appeals also felt that case-by-case adjudication was necessary to decide if a search of a person incident to a lawful arrest is justified.

Additional topics

Law Library - American Law and Legal InformationNotable Trials and Court Cases - 1973 to 1980United States v. Robinson - Significance, A Traditional Exception To The Warrant Requirement, A Long Tradition Of Case-by-case Adjudication