Law School Case Brief
United States v. Chadwick - 433 U.S. 1, 97 S. Ct. 2476 (1977)
Warrantless searches of luggage or other property seized at the time of an arrest cannot be justified as incident to that arrest either if the search is remote in time or place from the arrest or no exigency exists. Once law enforcement officers have reduced luggage or other personal property not immediately associated with the person of the arrestee to their exclusive control, and there is no longer any danger that the arrestee might gain access to the property to seize a weapon or destroy evidence, a search of that property is no longer an incident of the arrest.
After a footlocker had been lawfully seized by federal agents from the open trunk of a parked automobile during the arrests of those who were in possession of the footlocker at the automobile's location outside a train terminal, it was transported by federal agents to the federal building in Boston, Massachusetts. Federal agents, acting without a search warrant and without the consent of the arrested persons, but with a probable cause belief that the footlocker contained contraband, broke the lock and opened the footlocker in the federal building over an hour after the arrests and discovered large amounts of marijuana. Before their trial in the United States District Court for the District of Massachusetts on charges of, among other things, possession of marijuana with intent to distribute, those from whom the footlocker had been seized moved to suppress marijuana found during the search. The District Court granted the motion to suppress, holding that warrantless searches were per se unreasonable under the Fourth Amendment unless they fell within some established exception to the warrant requirement, and that the search of the footlocker without a warrant was not justified under either the exception for searches of automobiles or for searches incident to lawful arrests. The United States Court of Appeals for the First Circuit affirmed. Defendants petitioned for further review by the United States Supreme Court.
Was a search warrant required to open a locked footlocker that was seized during arrest, when there is probable cause to believe that the footlocker contains contraband?
The Court held that by placing personal effects inside a double-locked footlocker, defendants manifested an expectation that the contents would have remained free from public examination. The Court held that the expectation of privacy was no less than one who locked the doors of his home to intruders and that defendants were due the protection of U.S. Const. amend. IV's Warrant Clause. The Court held that there being no exigency it was unreasonable for the government to have conducted a search without the safeguards a judicial warrant provided. The Court held that the search was too remote to have been considered incident to arrest. The Court affirmed the order from the appellate court.
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