Law School Case Brief
United States v. Robinson - 414 U.S. 218, 94 S. Ct. 467 (1973)
Throughout the series of cases in which the Supreme Court of the United States has addressed the second proposition relating to a search incident to a lawful arrest, the permissible area beyond the person of the arrestee which such a search may cover, no doubt has been expressed as to the unqualified authority of the arresting authority to search the person of the arrestee.
Defendant Willie Robinson, Jr., was stopped by police for a motor vehicle violation. The police officer frisked Robinson for weapons in a manner pursuant to police department regulations and found in his pocket a crumpled container that contained capsules of heroin. A jury in federal district court convicted Robinson on the narcotics charges. Robinson appealed, and a division of the United States Court of Appeals for the District of Columbia reversed the conviction on the ground that the search of Robinson's person violated the commands of the Fourth Amendment. Upon rehearing en banc, however, the appellate court vacated the opinion and judgment of the division and remanded the case for an evidentiary hearing concerning the scope of the search of Robinson's person. On remand, the district court upheld the legality of the search. On appeal, the appellate court reversed, holding that the heroin had been obtained as the result of a search violative of the Fourth Amendment. The government was granted a writ of certiorari.
Was the police officer authorized to conduct a full search incident to the arrest of Robinson for a motor vehicle violation?
The Supreme Court of the United States reversed the appellate court's decision. The Court found that the arresting officer clearly was authorized to reach into Robinson's coat as part of his search because the officer had probable cause to arrest Robinson. Once probable cause to arrest was established, a full search incident to that arrest was authorized in order to protect the officer's safety and to preserve evidence. A police officer with probable cause to arrest a suspect, even where the arrest was for a traffic violation, was not limited to a protective frisk of the suspect's clothes for weapons, but rather was authorized to conduct a full search incident to the arrest.
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