Law School Case Brief
Carroll v. United States - 267 U.S. 132, 45 S. Ct. 280 (1925)
Where the facts and circumstances within police officers' knowledge and of which they had reasonably trustworthy information are sufficient in themselves to warrant a man of reasonable caution in the belief that intoxicating liquor is being transported in the automobile which the officers stop and search, the officers are justified in conducting the search.
Cronenwett and Scully, federal prohibition agents, where in an operation where they met three men to buy three cases of whiskey, including defendants George Carroll and John Kiro. The three men said they had to go to the east end of Grand Rapids, Michigan, to get the liquor and that they would be back in 30-45 minutes. They returned in an automobile known as an Oldsmobile Roadster but without the whiskey. Two months later, Cronenwett and other agents were patrolling the road leading from Detroit to Grand Rapids, looking for violations of the Prohibition Act. The officers were not anticipating that defendants would be coming through on the highway at that particular time, but when they met them there they believed they were carrying liquor. They stopped the car and searched it. They found behind 68 bottles of liquor hidden in the car seats. Defendants were arrested and later convicted in federal district court for transporting intoxicating spirituous liquor in a vehicle, in violation of § 26 of the National Prohibition Act. Defendants sought a writ of error, asserting that the warrantless search of the vehicle violated U.S. Const. amend. IV and that the liquor discovered as a result of the search should not have been admitted into evidence.
Was the warantless search and seizure valid?
The Supreme Court of the United States affirmed the district court's judgment. The Court found that the main purpose of § 26 of the National Prohibition Act was seizure and forfeiture, and that the right to search and the validity of the seizure were not dependent on the right to arrest, but were dependent on the reasonable cause the seizing liquor agents had for their belief that the contents of defendant's automobile were illegal. The evidence showed that the agents had ample reason to believe defendants' vehicle contained illegal liquor because defendants were known to transport liquor in that vehicle, were recognized by the agents, and were on a route known for illegal liquor traffic. Those circumstances provided sufficient probable cause to search the vehicle.
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