Law School Case Brief
United States v. Ross - 456 U.S. 798, 102 S. Ct. 2157 (1982)
A warrantless search of an automobile stopped by police officers who have probable cause to believe the vehicle contains contraband is not unreasonable within the meaning of U.S. Const. amend XIV.
Police officers, acting on information from an informant who previously had proved reliable, drove to a location specified by the informant and discovered a particular automobile which the informant had alleged contained narcotics in the trunk. After a brief period had elapsed, the officers, after noting that the automobile’s driver matched a description provided by the informant, stopped the car and opened its trunk. A closed paper bag was discovered that contained a white powder subsequently determined to be heroin. After a police officer drove the auto to headquarters, he thoroughly searched the car without obtaining a warrant, finding a zippered pouch containing $3200 in cash. The driver was convicted of possession of heroin with intent to distribute after the United States District Court for the District of Columbia denied his motion to suppress the heroin and currency. The United States Court of Appeals for the District of Columbia Circuit reversed, holding that the police should not have opened either container without first obtaining a warrant and rejecting the contention that it was reasonable for the police to open both the paper bag and pouch because they were entitled to conduct a warrantless search of the entire vehicle.
Was the warrantless search of the vehicle unreasonable under the Fourth Amendment, notwithstanding the fact that the police officers had probable cause to believe that the vehicle contained contraband?
On certiorari, the United States Supreme Court reversed and remanded, holding that police officers who have legitimately stopped an automobile and who have probable cause to believe that contraband was concealed somewhere within may conduct a warrantless search of the vehicle, including compartments and containers within the vehicle whose contents were not in plain view. According to the Court, the scope of a warrantless search of an automobile was defined by the object of the search, and the places in which there was probable cause to believe it would be found. The Court averred that probable cause justifying the search of a lawfully stopped vehicle justified the search its contents that could have concealed the object of the search.
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