United States v. Chadwick

United States v. Chadwick

United States Supreme Court
433 U.S. 1 (1977)

ISSUE: Is a warrantless search of a footlocker that the police have PC to believe contains the F&I of crime valid under the 4th Amdt. if it has been seized by police and under their exclusive control?
HOLDING: No, the footlocker is protected by the 4th Amdt. Warrant Clause, so it may only be searched with a warrant or under exigent circumstances.
FACTS:
  • Train officials saw D load a 200-lb. footlocker leaking talcum powder into a train heading for Boston
  • Police alerted officials in Boston who released their canine to sniff the trunk upon arriving, and the dog alerted the presence of drugs
  • Police arrested D and her companions when they loaded the footlocker into a car to leave
  • Police took the footlocker to the FBI building and it was under their exclusive control when they searched it without a warrant
PROCEDURAL HISTORY:
  • Indicted for possession of marijuana with intent to distribute
REASONING:
  • Footlocker protected by 4th Amdt.: By placing the lock on the footlocker, D manifested a subjective expectation of privacy for the contents inside, and the 4th Amdt. Warrant Clause protects that expectation
    • Exception if officers believe there are explosives inside
  • Vehicle exception doesn't apply: Just because the footlocker is mobile does not mean that it falls under the vehicle exception because luggage is intended as a repository for personal effects
    • Footlocker here was securely in police custody, so there was no risk of losing its contents
  • Not incident to arrest: Warrantless searches of luggage or other property seized at the time of an arrest cannot be justified as incident to arrest if the search is remote in time or place from the arrest
    • No danger that the arrestee might gain access to it

COMMENTS:

  • Take caution in how you use this case. I believe the major reason why this case graces a criminal procedure casebook is because is shows that not all "inherently mobile" objects will be relegated to the broad Vehicle Doctrine. A one-line summary for this case would be, "A footlocker is not a vehicle, so don't apply the Vehicle Doctrine."
  • You may want to refer to Bond v. United States for the interplay of "effects" and the Fourth Amendment.

 

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