Facts
- Police responded to a disturbance at a movie theater in Kankakee, Illinois, and arrested Ralph Lafayette for disturbing the peace after an altercation with the theater manager.
- Lafayette was handcuffed and transported to the police station for booking and jailing.
- Lafayette had a purse-type shoulder bag in his possession when arrested.
- During booking, an officer inventoried Lafayette’s possessions by removing and examining the contents of the shoulder bag.
- The officer discovered amphetamine pills inside a cigarette package within the bag.
- Lafayette was charged under the Illinois Controlled Substances Act based on the pills.
Issues
- Whether the Fourth Amendment permits police, without a warrant, to search a shoulder bag carried by an arrestee when the arrestee arrives at the station house for booking and jailing.
- Whether such a stationhouse search of personal effects is valid as a routine inventory search rather than requiring probable cause or a warrant.
- Whether the availability of less intrusive alternatives (e.g., sealing the bag) makes an otherwise routine inventory search unreasonable.
Decision
- The Supreme Court reversed the suppression order and held the search of Lafayette’s shoulder bag was a valid inventory search.
- The Court concluded it is reasonable under the Fourth Amendment for police to search the personal effects of a lawfully arrested person as part of routine administrative booking and jailing procedures.
- The Court held the justification for a stationhouse inventory search does not depend on probable cause; therefore, the lack of a warrant does not make the search unreasonable.
- The Court rejected the argument that police must use less intrusive alternatives instead of examining the contents of containers in the arrestee’s possession.
- Justice Marshall, joined by Justice Brennan, concurred in the judgment but expressed concern about overly broad approval of intrusive searches under the inventory rationale.
Legal Principles
- A routine stationhouse inventory of an arrestee’s personal effects is a recognized exception to the warrant requirement when conducted as part of administrative booking and jailing procedures.
- Inventory searches are justified by administrative and safety interests, including safeguarding the arrestee’s property, reducing theft and false claims against police, and preventing harm from dangerous items in custody.
- Police may open and inspect containers and items in the arrestee’s possession (including bags and smaller containers within them) as part of an established inventory procedure.
- The Fourth Amendment reasonableness inquiry does not require officers to employ the least intrusive means when a standardized inventory search is otherwise reasonable.
Conclusion
The Court held that a warrantless search of an arrestee’s shoulder bag during stationhouse booking, conducted as a routine inventory procedure, is reasonable under the Fourth Amendment, and evidence found during the inventory is admissible.