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Law School Case Brief

Florida v. Jimeno - 500 U.S. 248, 111 S. Ct. 1801 (1991)

Rule:

The touchstone of the Fourth Amendment is reasonableness. The Fourth Amendment does not proscribe all state-initiated searches and seizures; it merely proscribes those which are unreasonable. Thus, the court has long approved consensual searches because it is no doubt reasonable for the police to conduct a search once they have been permitted to do so. The standard for measuring the scope of a suspect's consent under the Fourth Amendment is that of objective reasonableness -- what would the typical reasonable person have understood by the exchange between the officer and the suspect.

Facts:

A police officer pulled over Enio Jimeno for a traffic violation after following him due to information that he may have been involved in a drug deal. Jimeno consented to a search of his car, but nothing more. The officer had informed Jimeno that he suspected him of having drugs in the car. The officer opened up a package and found cocaine inside. At trial, Jimeno argued that his consent to search his car did not extend to his permission to search within containers and packages. The lower court and the Florida Supreme Court upheld that Jimeno's consent did not cover the officer's efforts and thus ruled in Jimeno's favor. The State of Florida appealed to the United States Supreme Court.

Issue:

Was the search conducted by the officer reasonable and did it extend to the closed paper bag inside of the car?

Answer:

Yes.

Conclusion:

In a 7-2 vote, the Court overturned the lower courts' decision and ruled that the officer's search of containers within the car were not considered unreasonable. Since a reasonable person would expect narcotics to be carried in a container, and because the officer told Jimeno of his suspicions, the Court ruled that the officer acted within reason. Jimeno was thus found guilty and the officer was not in violation of the 4th amendment.

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