Rakas v. Illinois

by:

Following is the case brief for Rakas v. Illinois, 439 U.S. 128 (1978)

Case Summary of Rakas v. Illinois:

  • Police stopped a car after receiving a radio call that it may have been involved in a robbery. The officer searched the car after having petitioners, who were passengers in the car, step out. Evidence of the robbery was found in the car.
  • Petitioners were convicted of armed robbery after their motion to suppress the evidence in the car was denied.
  • On appeal, the appellate court affirmed denial of the motion to suppress.  It held that petitioners lacked standing to challenge the search on Fourth Amendment grounds because they did not own the car and claimed no possessory interest in the items seized.
  • The U.S. Supreme Court affirmed as well.  It held that because petitioners did not own the car or claim possession of the items seized, they had no expectation of privacy in the car.  They could not vicariously claim Fourth Amendment protection on behalf of the owner of the car.

Rakas v. Illinois Case Brief

Statement of the Facts:

A police officer in Illinois received a radio call of a robbery at a clothing store, and of the description of the getaway car.  Not long after the radio call, the officer spotted what appeared to be the getaway car and ordered the car to pull over.  The occupants of the car, petitioners and two female companions, were ordered out of the car.  Police then searched the inside of the car and found a sawed-off rifle and rifle shells.  Police arrested petitioners.

Before trial, petitioners moved to suppress the evidence found during the search of the car. Because petitioners conceded that they did not own the car or the items seized, the prosecutor argued that they lacked standing to challenge the search and seizure.

Procedural History:

  • The trial court denied petitioners’ motion to suppress the evidence from the car, and the prosecution later used the seized evidence at trial.  Petitioners were convicted of armed robbery.
  • On appeal, the Appellate Court of Illinois, Third Judicial District, affirmed the denial of the motion to suppress.  It found that passengers of a car that they do not own lack standing to challenge the legality of a search of the car.
  • The Illinois Supreme Court declined to hear the case.
  • The U.S. Supreme Court granted certiorari.

Issue and Holding:

Does a person have standing to challenge a search on Fourth Amendment grounds if he does not have a reasonable expectation of privacy in the area searched?  No.

Judgment:

The judgment of the Appellate Court of Illinois, Third Judicial District, is affirmed.

Rule of Law or Legal Principle Applied:

A person lacks standing to challenge a search on Fourth Amendment grounds if he does not have a reasonable expectation of privacy in the area searched.

Reasoning:

The Fourth Amendment right is a personal right that cannot be vicariously asserted.  Accordingly, evidence against a defendant uncovered in a search of a third party’s premises cannot be suppressed on the basis that the third party’s rights were violated.  The Court will not extend Fourth Amendment protection in such a scenario on the theory that the search was “directed” towards the defendant.

Further, petitioners cannot claim Fourth Amendment protection by being “legitimately on the premises” at the time of the search, consistent with Jones v. United States, 362 U.S. 257 (1960).  Jones is easily distinguishable.  The defendant in Jones was living in someone else’s apartment, and thus had some expectation of privacy in the apartment while he was there.  By contrast, petitioners did not acquire a privacy interest by merely being passengers in a car, particularly while claiming no possessory interest in the items seized during the search.

Concurring and Dissenting Opinions:

Concurring Opinion (Powell):

The dissent incorrectly characterizes the Court’s opinion.  The issue before the Court is a narrow one:  did the petitioners have an expectation of privacy in their friend’s car once they got out of it? The Court was correct to answer in the negative because the focus was properly on the petitioners’ legitimate expectation of privacy.

Dissenting Opinion (White):

The Court incorrectly holds that the Fourth Amendment protects property not people by finding that a person cannot challenge the search of vehicle if he or she does not own the car.  That rule seems to shield what is really going on, which is that the Court does not like the outcome based on the exclusionary rule in this case.  If that is true, the Court should confront the exclusionary rule directly, rather than fashion some indirect way to allow the result in this case to stand.

Significance:

Rakas v. Illinois is an important decision because it establishes the test of whether someone has standing to challenge a search on Fourth Amendment grounds — whether a person has a reasonable expectation of privacy in the place searched.  Here, a mere passenger in a car he does not own does not have a privacy interest that could be considered reasonable.

Student Resources:

https://supreme.justia.com/cases/federal/us/439/128/case.html

https://www.oyez.org/cases/1978/77-5781?sort=ideology