Once the accused is lawfully arrested and is in custody, the effects in his possession at the place of detention that were subject to search at the time and place of his arrest may lawfully be searched and seized without a warrant even though a substantial period of time has elapsed between the arrest and subsequent administrative processing and the taking of the property for use as evidence. This is true where the clothing or effects are immediately seized upon arrival at the jail, held under the defendant's name in the property room of the jail, and at a later time searched and taken for use at the subsequent criminal trial. The result is the same where the property is not physically taken from the defendant until sometime after his incarceration.
On May 31, 1970, at around 11 PM, the defendant Edwards was lawfully arrested, taken to the local jail and placed in a cell. The next morning trousers and a shirt were purchased for him to substitute for the clothing which he had been wearing at the time of and since his arrest. His clothing was then taken from him, examined, and held as evidence. At his trial, which resulted in conviction, this evidence was received over his objection that neither the clothing nor the results of its examination were admissible because the warrantless seizure of his clothing was invalid under the Fourth Amendment. His conviction was reversed by the Court of Appeals, which held that although the arrest was lawful, the warrantless seizure of the clothing, carried out after the administrative process and mechanics of arrest had come to a halt, was unconstitutional under the Fourth Amendment.
Did the warrantless seizure of the defendant’s clothing violate the Fourth Amendment?
The Court held that the search and seizure of Edwards' clothing did not violate the Fourth Amendment. The Court ruled that the search and seizure of the defendant’s clothing was a normal incident of custodial arrest and that it was reasonable because of the existence of probable cause linking the clothes to the crime. Furthermore, it was held that once an accused has been lawfully arrested and is in custody, the effects in his possession at the place of detention that were subject to search at the time and place of arrest may lawfully be searched and seized without a warrant even after a substantial time lapse between the arrest and later administrative processing, on the one hand, and the taking of the property for use as evidence, on the other.