Chambers v. Maroney

Chambers v. Maroney

United States Supreme Court
399 U.S. 42 (1970)

ISSUE: Is a warrantless seizure of a vehicle unreasonable under the 4th Amdt. if the officers had PC to believe that the fruits and instrumentalities of crime would be found inside?
HOLDING: No, there is no constitutional difference between a warrantless search of the vehicle and a warrantless seizure (both are valid under the 4th Amdt. with PC).
FACTS:
  • A service station was robbed, and the attendant told the officers that one of the robbers was wearing a green sweater and the other was wearing a trench coat
  • Teenagers had earlier reported to police that they saw a car circling the block with occupants matching the same description
  • Officer put out an APB on the descriptions, and the car was seen with the occupants matching the description
  • The occupants were arrested, and the car was taken to the police station where a thorough search of the car was done
PROCEDURAL HISTORY:
  • Convicted of both robberies
RULES:
  • Carroll v. United States: Automobiles and other conveyances may be searched without a warrant in circumstances that would not justify the search without a warrant of a house or an office, provided that there is PC to believe that the car contains articles that the officers are entitled to seize
    • Not dependent on the right to arrest
REASONING:
  • Warrantless search of car OK: Cars are movable, so if a search is to be done, it must be done immediately or risk losing the fruits and instrumentalities of crime
    • No constitutional difference between an immediate warrantless search of a car and a warrantless seizure of a car until a warrant to search is obtained
    • NEED PC to believe that the fruits or instrumentalities of crime will be found inside, however
  • Search here OK: Officers had PC to believe that the F&I of crime would be found inside, so the warrantless seizure was valid under the 4th Amdt.

COMMENTS:

  • To sum up probable-cause-based vehicle searches, PC = search. So long as the law enforcement officer has probable cause to believe that the fruits and instrumentalities of crime will be found in the vehicle she is justified in searching the vehicle on the spot or seizing the vehicle and searching it later.
  • See California v. Carney for the justification for the so-called "Vehicle Doctrine."

 

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