## Facts

- California police surveilled an apartment suspected of marijuana trafficking and knew a Federal Express package containing marijuana had been delivered there.
- Officers observed Charles Steven Acevedo enter the apartment and leave carrying a brown paper bag similar in size to packages of marijuana previously observed.
- Acevedo placed the bag in the trunk of his car and drove away.
- Police stopped the car, opened the trunk, and searched the bag without a warrant, finding marijuana.
- Acevedo moved to suppress the marijuana as the product of an unlawful warrantless search; the trial court denied the motion, and Acevedo pleaded guilty to possession of marijuana for sale.

## Issues

1. Whether the Fourth Amendment permits a warrantless search of a container located in an automobile when officers have probable cause to believe the container holds contraband, but lack probable cause to search the entire vehicle.

## Decision

- The Supreme Court reversed the California Court of Appeal in a 6–3 decision.
- The Court held that police may search a container within an automobile without a warrant when they have probable cause to believe the container holds contraband or evidence.
- The Court adopted a single rule for automobile searches: officers may search an automobile and the containers within it where they have probable cause to believe contraband or evidence is contained.
- The Court overruled prior precedent in part to the extent it required a warrant when probable cause was directed only at a container placed in a vehicle.

## Legal Principles

- Under the automobile exception, probable cause permits a warrantless search of a vehicle and any containers within it that could conceal the object of the search.
- Probable cause need not be “compartmentalized” between the vehicle and a specific container when the container is located in a readily mobile automobile.
- The Fourth Amendment does not require a separate warrant for a container in a car merely because probable cause focuses on the container rather than the vehicle as a whole.
- Stare decisis does not require retention of a rule that is unworkable, yields arbitrary distinctions, and provides minimal additional privacy protection in practice.

## Conclusion

The Court held that the automobile exception authorizes a warrantless search of a container found in a vehicle when officers have probable cause to believe the container contains contraband or evidence, eliminating the prior container-specific warrant requirement for such automobile searches.


California v. Acevedo, 500 U.S. 565 (1991)