Law School Case Brief
Robbins v. California - 453 U.S. 420, 101 S. Ct. 2841 (1981)
Unless a container is such that its contents may be said to be in plain view, those contents are fully protected by the Fourth Amendment.
California Highway Patrol officers stopped a 1966 station wagon because they observed the vehicle being driven erratically. Upon smelling marihuana smoke, one of the officers patted the driver, defendant Jeffrey Richard Robbins, down, discovering a vial of liquid, and then searched the passenger compartment of the car, finding marihuana as well as equipment for using it. After placing Robbins in the patrol car, the officers opened the tailgate of the station wagon, located a handle set flush in the deck, and lifted it up to uncover a recessed luggage compartment. In the compartment were two packages wrapped in green opaque plastic which the officers then unwrapped and found to contain bricks of marihuana. Robbins was subsequently charged with various drug offenses, his pretrial motion to suppress the evidence found when the packages were unwrapped was denied, and he was convicted. The Court of Appeal of California affirmed the conviction, ruling that the warrantless opening of the packages was constitutionally permissible since the trial court could reasonably have concluded that the contents of the packages could have been inferred from their outward appearance, such that Robbins could not have held a reasonable expectation of privacy with respect to the contents. The United States Supreme Court granted defendant's petition for certiorari.
Did the warrantless opening of packages wrapped in opaque plastic discovered in luggage compartment during course of lawful warrantless search of automobile violative of Fourth Amendment?
The United States Supreme Court held that the search of the containers was unlawful because the automobile exception to the warrant requirement did not extend to the containers. The Court reasoned that the contents of the containers were immune from a warrantless search because, by placing the contents into closed, opaque containers, defendant reasonably manifested an expectation that the contents would remain free from public examination. The Court noted that the containers did not so clearly announce their contents as to fall within the exception for packages open to plain view.
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