Law School Case Brief
United States v. Place - 462 U.S. 696, 103 S. Ct. 2637 (1983)
The exception to the probable-cause requirement for limited seizures of the person recognized in Terry and its progeny rests on a balancing of the competing interests to determine the reasonableness of the type of seizure involved within the meaning of the Fourth Amendment's general proscription against unreasonable searches and seizures. Courts must balance the nature and quality of the intrusion on the individual's Fourth Amendment interests against the importance of the governmental interests alleged to justify the intrusion.
When defendant's behavior aroused the suspicion of law enforcement officers as he waited in line at the Miami International Airport to purchase a ticket to New York's La Guardia Airport, the officers approached defendant and requested and received identification. Defendant consented to a search of the two suitcases he had checked, but because his flight was about to depart, the officers decided not to search the luggage. The officers then found some discrepancies in the address tags on the luggage and called Drug Enforcement Administration (DEA) authorities in New York to relay this information. Upon defendant's arrival at La Guardia Airport, two DEA agents approached him, said that they believed he might be carrying narcotics, and asked for and received identification. When defendant refused to consent to a search of his luggage, one of the agents told him that they were going to take it to a federal judge to obtain a search warrant. The agents then took the luggage to Kennedy Airport where it was subjected to a "sniff test" by a trained narcotics detection dog, which reacted positively to one of the suitcases. At this point, 90 minutes had elapsed since the seizure of the luggage. Thereafter, the agents obtained a search warrant for that suitcase and upon opening it discovered cocaine. Defendant was indicted for possession of cocaine with intent to distribute, and the District Court denied his motion to suppress the contents of the suitcase. He pleaded guilty to the charge and was convicted, but reserved the right to appeal the denial of his motion to suppress. The Court of Appeals reversed, holding that the prolonged seizure of defendant's luggage exceeded the limits of the type of investigative stop permitted and amounted to a seizure without probable cause in violation of the Fourth Amendment. The United States sought further review from the United States Supreme Court.
Did the 90 minute seizure of defendant's person and luggage violate the Fourth Amendment?
The Court affirmed the reversal of defendant's conviction on the basis that the evidence obtained from the search was inadmissible. The 90-minute detention of defendant's luggage went beyond the narrow authority possessed by police to detain briefly luggage reasonably suspected to contain narcotics. The violation was exacerbated by the agents' failure to accurately inform the defendant where they were transporting his bags, how long he might be dispossessed, and what arrangements would be made for return of the bags if the investigation dispelled the suspicion. Under the circumstances, the seizure of defendant's luggage violated the Fourth Amendment. Accordingly, the evidence obtained from the subsequent search of the luggage was inadmissible, and defendant's conviction must be reversed.
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