Rakas v. Illinois

Rakas v. Illinois Case Brief

United States Supreme Court
439 U.S. 128 (1978)

ISSUE: May passengers in an automobile that was the subject of an unconstitutional search and seizure assert the exclusionary rule to exclude the evidence obtained from that search and seizure against them?
HOLDING: No.
FACTS:
  • Ds were passengers in a car that was stopped because police believed it matched the description of a car used as a robbery getaway car
  • Occupants were ordered out of the car, and it was then searched
  • A box of rifle shells in the locked glove compartment and a sawed-off rifle on the front passenger seat were seized
PROCEDURAL HISTORY:
  • Ds moved to exclude the evidence as being violative of the 4th Amdt.
  • Trial judge concluded that they lacked standing and denied the suppression motion
REASONING:
  • Reject "target theory": Exclusionary rule for 4th Amdt. violations does not extend to violations of 4th Amdt. rights of 3rd parties
    • 4th Amdt. rights are personal rights
    • Exclusionary rule seeks to effectuate the guarantees of the 4th Amdt., so it is proper to permit only those Ds whose rights have been violated to benefit from the rule's protections
  • Abandon distinction: The better analysis in "standing" cases is to focus on the extent of a particular D's rights under the 4th Amdt., rather than relying on any separate but intertwined concept of standing
    • Question is whether the challenged search or seizure violated a D's 4th Amdt. rights who seeks to exclude the evidence obtained during it
  • Jones test not valid: The "legitimately on premises" phrase coined in Jones creates too broad a gauge for measuring 4th Amdt. rights
    • Jones merely standings for the proposition that one may have a legally sufficient interest in a place other than his home to be protected against governmental intrusions into that place
    • Phrase at best gives superficial clarity to determining whether one's 4th Amdt. rights were violated
  • Ds claims invalid: Ds had neither a property nor a possessory interest in the car, nor an interest in the property seized
    • The fact that they were "legitimately on the premises" is insufficient to determine that their 4th Amdt. rights were violated
COMMENTS:
  • Rakas: 4th Amdt. rights are personal rights
  • 4th Amdt. claims in vehicle stops:
    • If the stop itself was illegal, then everyone in the car has a suppression claim
    • But if the stop was legal, but the search was illegal, then the passengers don't have a suppression claim (need a possessory interest)
  • No suppression claim for passengers: Passengers had no suppression claim because they showed no property or possessory interest in the car NOR and interest in the things seized
    • Property interests are not dispositive; they can be overcome by the totality of the factors (who was the driver, who's on the title, sleeping in car, caring for car, spare key) -- need to treat the car as one's own
  • Pennsylvania v. Mimms: Police can order everyone out of a car during a traffic stop, and if officer has reasonable suspicion, officer can do a Terry patdown of the occupants
OTHER CASES:
  • Alderman v. United States: Suppression of the product of a 4th Amdt. violation can be successfully urged by only those whose rights were violated by the search itself, not by those who are aggrieved solely by the introduction of the damaging evidence
    • 4th Amdt. rights are personal rights and cannot be asserted vicariously
  • Minnesota v. Olson: In general, an overnight guest has a legitimate expectation of privacy in his host's home despite not having a legal interest in the premises
    • Question of intent of the owner and intent of the guest to stay the night (toothbrush, clothes there, spent the night there before, spend nights at people's houses frequently, etc.)
    • Don't actually have to spend the night, just have the requisite intent to stay the night
    • Act of sleeping put someone in a particularly vulnerable position
  • Rawlings v. Kentucky: Ownership of the property seized as the result of a search does not by itself entitle an individual to challenge the search
    • The individual must demonstrate that his or her legitimate expectation of privacy was violated by search
    • Ownership is but one factor to consider
  • Simmons v. United States: A D's admission of ownership of contraband at a suppression hearing in order to establish "standing" cannot be used as substantive proof of guilt against him at trial
    • No longer need "automatic standing" rule when one is charged with possession of contraband
    • What-Happens-in-Vegas-Stays-in-Vegas Rule
    • BUT testimony at suppression hearing can be used by prosecution to impeach D at trial
    • So D can really only testify at one hearing or the other
  • United States v. Payner: IRS agents were told to deliberately ignore the 4th Amdt.'s prohibition against unreasonable seizures and search the briefcase of a banker in order to charge the banker's customers
    • HELD, banker's customers still do not have "standing" to bring a 4th Amdt. claim for suppression despite the bad faith of the IRS

Leave a Reply