Law School Case Brief
South Dakota v. Opperman - 428 U.S. 364
The Supreme Court has traditionally drawn a distinction between automobiles and homes or offices in relation to U.S. Const. amend. IV. Although automobiles are effects and thus within the reach of U.S. Const. amend. IV, warrantless examinations of automobiles have been upheld in circumstances in which a search of a home or office would not.
Respondent's car was towed to a city impound lot. From outside the car at the impound lot, a police officer observed a watch on the dashboard and other items of personal property located on the back seat and back floorboard. At the officer's direction, the car door was then unlocked and, using a standard inventory form pursuant to standard police procedures, the officer inventoried the contents of the car, including the contents of the glove compartment, which was unlocked. The officer found marijuana in the glove compartment. Respondent was arrested and convicted on charges of possession. His motion to suppress the evidence was denied. The Supreme Court of South Dakota held that local police violated the Fourth Amendment, as applicable to the states under the Fourteenth Amendment, when they conducted a routine inventory search of an automobile lawfully impounded by police for violations of municipal parking ordinances. The state supreme court concluded that the evidence had been obtained in violation of the Fourth Amendment's prohibition against unreasonable searches and seizures. The State sought review.
Did police officers violate the Fourth Amendment when they conducted a warrantless but reasonable search of a lawfully impounded vehicle?
On certiorari, the Supreme Court of the United States reversed the judgment. The Court reasoned that the owner, having left his car illegally parked for an extended period and thus subject to impoundment, was not present to make other arrangements for the safekeeping of his belongings. Further, the inventory itself was prompted by the presence in plain view of a number of valuables inside the car. The Court held that there was no suggestion whatever that the standard procedure was a pretext concealing an investigatory police motive. The Court concluded that in following standard police procedures the conduct of the police was not unreasonable under Fourth Amendment.
This Court explained that the expectation of privacy as to automobiles is further diminished by the obviously public nature of automobile travel. In the interests of public safety and as part of what the Court has called "community caretaking functions," automobiles are frequently taken into police custody. When the police take custody of any sort of container such as an automobile, it is reasonable to search the container to itemize the property to be held by the police. This reflects the underlying principle that the Fourth Amendment proscribes only unreasonable searches.
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