## Facts

- Chester J. Dombrowski, a Chicago police officer, crashed a rented Ford Thunderbird near Kewaskum, Wisconsin, and was arrested for drunk driving.
- The Ford was towed to a private garage and left unguarded outdoors; local police treated it as a disabled vehicle creating a traffic hazard.
- Officers believed, based on his status as a police officer and departmental practice, that Dombrowski likely had a service revolver that could be in the car.
- The next morning, an officer conducted a warrantless search of the Ford for the revolver and opened the trunk, finding and removing several bloody items.
- Information later led officers to Dombrowski’s brother’s farm, where they discovered a blood-stained body near a disabled Dodge automobile.
- Officers observed bloodied items inside the Dodge through the windows and obtained a search warrant for the Dodge.
- During execution of the warrant, officers seized items including a sock and a floor mat; those items were not listed in the warrant return.
- Dombrowski was convicted of murder in Wisconsin; state courts affirmed.
- In federal habeas proceedings, the district court denied relief, but the Seventh Circuit granted relief, finding unconstitutional seizure of certain evidence.

## Issues

1. Whether the warrantless search of the disabled Ford’s trunk for a suspected service revolver, and seizure of bloody items found there, violated the Fourth and Fourteenth Amendments.
2. Whether seizure of the sock and floor mat from the Dodge was unconstitutional because they were not listed in the warrant return.

## Decision

- The Supreme Court reversed the Seventh Circuit and upheld admission of the challenged evidence.
- The warrantless search of the Ford was reasonable under the Fourth Amendment because police had taken custody of a disabled vehicle posing a roadway hazard and searched for a firearm to protect the public under standard police practice.
- The officers’ discovery and seizure of incriminating items during that caretaking search did not make the initial search unreasonable.
- The seizure of the sock and floor mat from the Dodge was valid because the warrant particularly described the Dodge and was still outstanding when the items were found; the later warrant return did not limit the warrant’s scope during execution.

## Legal Principles

- Fourth Amendment reasonableness can permit a warrantless vehicle search when police are performing community-caretaking functions separate from criminal investigation, including safeguarding the public from a firearm in an unattended vehicle under police custody.
- Reasonableness is evaluated based on the circumstances confronting officers at the time, not post hoc judicial evaluation.
- A valid warrant’s authority depends on the warrant as issued and outstanding at execution; omissions or defects in the subsequent warrant return do not retroactively invalidate a lawful seizure made while the warrant remained in effect.

## Conclusion

The Court held that police may conduct certain warrantless vehicle searches as part of community-caretaking duties when undertaken for public safety pursuant to standard procedures, and that a lawful seizure made during execution of a valid vehicle warrant is not rendered unconstitutional by the item’s omission from the later warrant return.


Cady v. Dombrowski, 413 U.S. 433 (1973)