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Law School Case Brief

Chambers v. Maroney - 399 U.S. 42, 90 S. Ct. 1975 (1970)

Rule:

The validity of an arrest is not necessarily determinative of the right to search a car if there is probable cause to make the search. In many cases the circumstances justifying the arrest are also those furnishing probable cause for the search.

Facts:

After the second armed robbery within a week had occurred, the police were given a description of the robbers' car and of the clothing worn by two of the four men seen in the car. Within an hour the police stopped a car that met the description and which was carrying four men and the described clothing. Petitioner Frank Chambers was one of the four men in the car. The police conducted a warrantless search of the car at the station and found two revolvers, ammunition, and property stolen in the robberies. They also searched Chambers' home and found more ammunition of the same type as that found in the car. Chambers was tried for both robberies in Pennsylvania state court, but his first trial ended in a mistrial. At the second trial, the materials found through the searches were admitted in evidence, the victim of each robbery identified the Chambers as one of the robbers, and Chambers was convicted and given consecutive sentences for the two robberies. After the state courts denied his request for habeas corpus relief, he petitioned for habeas corpus in federal district court, which denied the petition. The court of appeals affirmed. Chambers was granted a writ of certiorari. 

Issue:

Did the warrantless search of the car after Chambers' arrest violate the Fourth Amendment?

Answer:

No.

Conclusion:

The Supreme Court of the United States affirmed the denial of Chambers' petition for a writ of habeas corpus. The Court held that the warrantless search of the suspects' car at the police station after Chambers and the other occupants were arrested for robbery did not violate the Fourth Amendment. The police had probable cause to stop the vehicle and to search it immediately at the time and place of arrest. The requirement of probable-cause still applied at the police station, and it was reasonable for police to take the car there before making the search. The Court also ruled that the district court properly denied Chambers a hearing on his claim pertaining to his right to the effective assistance of counsel.

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