Law School Case Brief
Rakas v. Illinois - 439 U.S. 128, 99 S. Ct. 421 (1978)
Capacity to claim the protection of U.S. Const. amend. IV depends not upon a property right in the invaded place but upon whether the person who claims the protection of the amendment has a legitimate expectation of privacy in the invaded place.
After receiving a robbery report, police stopped the suspected getaway car, which the owner was driving and in which petitioner Rakas and others were passengers. Upon searching the car, the police found a box of rifle shells in the glove compartment and a sawed-off rifle under the front passenger seat. Petitioners were arrested and later were convicted in Illinois state court of armed robbery. At trial, petitioners moved to suppress the rifle and shells on Fourth Amendment grounds, but the trial court denied the motion on the ground that petitioners lacked standing to object to the lawfulness of the search of the car because they concededly did not own either the car or the rifle and shells. The rifle and shells were admitted as evidence. An Illinois appellate court affirmed the convictions. Petitioners sought certiorari review of the decision.
By searching the car in which petitioners were passengers, did the police officers violate petitioners' Fourth Amendment rights?
The Supreme Court of the United States held that petitioners were not entitled to challenge the search as violative of the Fourth Amendment, since the search did not violate any of their rights. The Court averred that the appropriate measure of rights was no longer guided solely by whether petitioners were legitimately on the premises that the police searched. Without holding that a property interest was required, the Court decided that U.S. Const. amend. IV protected only those places in which petitioners themselves had a reasonable expectation of privacy. Using this analysis, the Court found that petitioners' rights were not violated where they had no legitimate expectation of privacy in areas of a car in which they claimed no property or possessory interest.
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