California v. Acevedo
Following is the case brief for California v. Acevedo, Supreme Court of the United States, (1991).
Case summary for California v. Acevedo:
- Acevedo was spotted carry a bag out of a house that was under police surveillance.
- Officers had probable cause to believe the bag, which Acevedo placed in his trunk, contained contraband.
- Officers then pulled over Acevedo, recovering the bag, which contained marijuana, from his truck. Acevedo claimed that the search violated the Fourth Amendment.
- The Court held that officers may perform a warrantless search of an automobile when they have probable cause the container is holding contraband.
California v. Acevedo Case Brief
Statement of the facts:
Prior to obtaining a search warrant, officers watched a man walk into his home while carrying a package which officers had probable cause to believe contained marijuana inside. Shortly after, Acevedo entered and then exited the home, holding a bag, which he placed into his trunk and left. The officers decided to follow Acevedo and pull him over out of fear that evidence might be lost. After pulling Acevedo over, officers found marijuana in the bag Acevedo placed in his trunk. Acevedo plead guilty to a possession charge.
Procedural History:
The state court of appeals held that the marijuana should have been suppressed because the officers needed a warrant to search the bag. The state petitioned to the Supreme Court of the United States, and the Court granted certiorari.
Rule of Law or Legal Principle Applied:
Under the Fourth Amendment, police may conduct a warrantless search of an automobile when they have probable cause the container is holding contraband.
Statement of the facts:
Prior to obtaining a search warrant, officers watched a man walk into his home while carrying a package which officers had probable cause to believe contained marijuana inside. Shortly after, Acevedo entered and then exited the home, holding a bag, which he placed into his trunk and left. The officers decided to follow Acevedo and pull him over out of fear that evidence might be lost. After pulling Acevedo over, officers found marijuana in the bag Acevedo placed in his trunk. Shortly after, Acevedo plead guilty to a possession charge.
Procedural History:
The state court of appeals held that the marijuana should have been suppressed because the officers needed a warrant to search the bag. The state petitioned to the Supreme Court of the United States, and the Court granted certiorari.
Rule of Law or Legal Principle Applied:
Under the Fourth Amendment, police may conduct a warrantless search of an automobile when they have probable cause the container is holding contraband.
Issue and Holding:
Do the police need to obtain a warrant in order to search a container in a moving vehicle, if they have probable cause that the container in the car contains illegal contraband, according to the Fourth Amendment? No.
Judgment:
The Court reversed the lower court’s holding.
Reasoning:
The Court held that under the Fourth Amendment, a warrantless search of a container in a vehicle is permitted when the police have probable cause that contraband is located inside of the container. This is similar to how the Fourth Amendment permits a warrantless search of a car when police can establish probable cause that there is contraband in the vehicle.
The Court points out that a container found subsequent to both a general and specific search, can easily be hidden or ruined. Both the exigent circumstances and expectations in privacy in finding a container are the same and warrant equal treatment, regardless of the general or specific status.
Additionally, the Court ruled that having two separate rules for when probable cause exists for a car and a container located in a car, would yield confusion and more far-reaching searches than necessary.
An officer can search the container absent a warrant, in the event he or she has probable cause that a specific container located in a car, which is in transit, holds contraband. Such a search must be limited to the specific container, unless probable cause exists that the car itself contains contraband too.
Here, the search of Acevedo’s bag located in his trunk was constitutional since officers possessed probable cause that the specific bag contained contraband.
Concurring or Dissenting opinion:
Concurring (Scalia):
The search was constitutional. This is because under the Fourth Amendment, a warrantless search of a closed container where probable cause has been established is reasonable.
Dissenting (Stevens):
The Court’s opinion is incorrect as it fails to identify any exigent circumstances which might merit the construction of a new rule. The Court draws unsupported presumptions to justify its holding that the current rules fail to protect significant privacy interest and encumber law enforcement from performing their job.
Significance:
This case set out the precedent that police who already have established probable cause regarding the contents of a contained located in a moving car, may conduct a search of that container without a search warrant.
Student Resources:
https://supreme.justia.com/cases/federal/us/500/565/case.html
