Facts
- A Pennsylvania service station was robbed at gunpoint.
- Witnesses promptly gave police the make and color of the getaway car and clothing descriptions for two perpetrators.
- Police soon stopped a car matching the description with four occupants; two matched the clothing descriptions.
- Police arrested the occupants and drove the car to the police station.
- At the station, officers conducted a warrantless search of the car and found two revolvers (including one loaded with dumdum bullets) and cards bearing the name of an attendant at another recently robbed station.
- The next day, police searched Chambers’s home under a warrant and seized ammunition, including dumdum bullets similar to those found in the car.
- At Chambers’s second trial (after a mistrial), the vehicle items and the ammunition were admitted into evidence.
- Chambers claimed Fourth Amendment violations (car search and home search) and ineffective assistance of counsel based on last-minute substitution of appointed counsel with minimal pretrial consultation.
- State and federal courts denied habeas relief; the Supreme Court affirmed.
Issues
- Whether the Fourth Amendment permits a warrantless automobile search conducted at the police station after the car is seized and moved there, when police had probable cause at the time of the stop.
- Whether admission of ammunition seized from Chambers’s home warranted relief, or was harmless beyond a reasonable doubt.
- Whether last-minute substitution of counsel and minimal pretrial consultation denied Chambers effective assistance of counsel.
Decision
- The Court affirmed the denial of habeas relief.
- The warrantless station-house search of the automobile was valid, and the items found in the car were properly admitted.
- Even assuming error in admitting ammunition seized from the home, any error was harmless beyond a reasonable doubt.
- Chambers did not establish a constitutional denial of effective assistance of counsel.
Legal Principles
- Under the automobile exception, if police have probable cause to search a vehicle, they may conduct a warrantless search because of the vehicle’s mobility and reduced practical feasibility of obtaining a warrant.
- For Fourth Amendment purposes, where probable cause exists, there is no constitutional difference between (a) conducting an immediate warrantless search of a vehicle and (b) seizing the vehicle, moving it, and conducting the warrantless search later at the station.
- A search conducted at the station some time after arrest is not justified as a search incident to arrest; its validity must rest on probable cause and the automobile exception.
- Habeas relief is unavailable where an evidentiary error, if any, is harmless beyond a reasonable doubt.
- Ineffective-assistance claims require a showing of prejudice; lack of preparation or late substitution, without demonstrated prejudice affecting the outcome, does not establish a constitutional violation.
Conclusion
The Court held that probable cause to search a vehicle permits a warrantless search even after the car is taken to the police station, treated any possible error in admitting ammunition from a home search as harmless beyond a reasonable doubt, and rejected the ineffective-assistance claim for lack of demonstrated prejudice.