Illinois v. Lafayette

Illinois v. Lafayette

United States Supreme Court
462 U.S. 640 (1983)

ISSUE: Was it unreasonable under the 4th Amdt. for an officer to search the contents of D's shoulder bag upon arresting him and before incarcerating him if the officer found contraband inside?
HOLDING: No, it is not "unreasonable" for police, as part of the routine procedure incident to incarcerating an arrested person, to search any container or article in his possession, in accordance with established inventory procedures.
FACTS:
  • D was arrested for disturbing the peace at a cinema and taken to the police station
  • An officer searched D's shoulder bag to inventory the contents and found 10 amphetamine pills inside
RULES:
  • Delaware v. Prouse: Balance the intrusion on the individual's 4th Amdt. interests against its promotion of legitimate government interests
REASONING:
  • More intrusive search can be done at station: What would be impracticable or unreasonable on the street as far as searching can more readily and privately be performed at the station
    • Don't need a warrant or PC
  • Police admin. considerations: Examining all the items removed from the arrestee's person or possession and inventorying them is an entirely reasonable administrative procedure
  • Search was reasonable: It is not "unreasonable" for police, as part of the routine procedure incident to incarcerating an arrested person, to search any container or article in his possession, in accordance with established inventory procedures
    • Doesn't depend on whether there were less intrusive means avaiable

 

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