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Law School Case Brief

Stoner v. California - 376 U.S. 483, 84 S. Ct. 889 (1964)

Rule:

A search can be incident to an arrest only if it is substantially contemporaneous with the arrest and is confined to the immediate vicinity of the arrest.

Facts:

Defendant Joey L. Stoner was a suspect in an armed robbery. After police officers obtained information where defendant was staying, they went to the hotel and received permission from the night clerk to enter defendant's room, where they seized evidence without a warrant. A jury convicted defendant of armed robbery, which was affirmed on appeal. The Supreme Court of California denied further review. Defendant sought certiorari review, arguing that the evidence was obtained in violation of his constitutional rights against unreasonable search and seizure. The State argued that the search was an incident to a lawful arrest, and in any case, the hotel clerk gave permission to the officers for the search.

Issue:

Did the trial court err in determining that the search of the hotel room was an incident to a lawful arrest, which rendered the evidence seized admissible as evidence against defendant?

Answer:

No.

Conclusion:

The United States Supreme Court reviewed the record, which indicated that defendant's arrest occurred two days later in another state, and therefore, the arrest could not be the basis for the warrantless search. The Court also held that defendant had a reasonable expectation of privacy in his hotel room and that the hotel clerk did not have authority to give permission to the officers to search defendant's room. Accordingly, the Court concluded that the evidence that the officers seized was inadmissible in defendant's trial and reversed his conviction.

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