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Law School Case Brief

Illinois v. Lafayette - 462 U.S. 640, 103 S. Ct. 2605 (1983)

Rule:

The inventory search constitutes a well-defined exception to the warrant requirement. Probable cause to search is irrelevant in inventory searches because the salutary functions of a warrant simply have no application in that context; the constitutional reasonableness of inventory searches must be determined on other bases.

Facts:

Defendant was arrested for disturbing the peace, but he was subsequently charged with violating the state's controlled substances statute when narcotics were found in his bag during the routine booking procedure. The trial court granted defendant’s motion to suppress the narcotics that were found in his bag. The district appellate court affirmed, and the State sought review.

Issue:

Did the trial court err in granting defendant’s motion to suppress the narcotics that were found in his bag during the routine booking procedure?

Answer:

Yes.

Conclusion:

The Court reversed and remanded the judgment below. The court held that the warrantless search of defendant's shoulder bag, which was conducted pursuant to standard booking procedures as an inventory of defendant's belongings, was not unreasonable under the Fourth Amendment. The narcotics found in the bag were thus improperly suppressed.

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