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Law School Case Brief

Rawlings v. Kentucky - 448 U.S. 98, 100 S. Ct. 2556 (1980)

Rule:

One who challenges an allegedly illegal search bears the burden of proving not only that the search was illegal, but also that he had a legitimate expectation of privacy in the area to be searched.

Facts:

Defendant was convicted in commonwealth court of trafficking in, and possession of, various controlled substances. The Supreme Court of Kentucky affirmed his conviction. The court granted certiorari to hear defendant's challenge to his conviction. Defendant argued that certain evidence and statements were inadmissible in his criminal trial on the grounds that they were the fruits of an illegal detention and illegal searches. Defendant was arrested after a search warrant was executed on a residence that he was visiting. After drugs were found in a purse of a female companion, defendant admitted ownership of the drugs to law enforcement officers. He argued that he had a reasonable expectation of privacy in the purse so as to allow him to challenge the legality of the search, and his admission of ownership of the drugs was the fruit of an illegal detention.

Issue:

Did petitioner sustain the burden of proof that he had legitimate expectation of privacy in the purse of a female companion?

Answer:

No

Conclusion:

Defendant’s conviction was affirmed. The court found that defendant did not have a legitimate expectation of privacy in the purse at the time of the search. The court also found that after examining the totality of circumstances present in the case, the prosecution had carried its burden of showing that defendant's statements were acts of free will unaffected by any illegality in the initial detention. The court found that money and a knife that were discovered on defendant's person were lawfully obtained from a search incident to his formal arrest.

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