Facts
- Philadelphia police observed Edwin Labron involved in street-level drug transactions in which drugs were produced from a car’s trunk.
- After arrests, officers searched the car’s trunk without a warrant and found bags of cocaine.
- In a related investigation, an undercover informant arranged a drug purchase involving Randy Kilgore and an accomplice who traveled to a farmhouse to obtain drugs from Kilgore.
- After arrests, police searched the farmhouse with the owner’s consent and searched Kilgore’s pickup truck parked in the driveway, finding cocaine on the truck’s floor.
- In both cases, probable cause to search the vehicles was effectively conceded or not seriously disputed.
Issues
- Whether the Fourth Amendment requires police to obtain a warrant to search an automobile absent additional exigent circumstances, even when officers have probable cause.
Decision
- The Supreme Court reversed the Pennsylvania Supreme Court in both cases and remanded.
- The Court held that the automobile exception “requires only that there be probable cause to conduct a search.”
- The Court rejected the state court’s view that warrantless vehicle searches also require a separate showing of exigent circumstances beyond the vehicle’s ready mobility.
Legal Principles
- Under the Fourth Amendment automobile exception, a warrantless search of a vehicle is permitted when police have probable cause to believe the vehicle contains contraband or evidence.
- The automobile exception has no separate, case-specific exigency requirement; a vehicle’s ready mobility supplies the exigency once probable cause exists.
- Reduced expectations of privacy in automobiles, due in part to pervasive regulation, support application of the exception.
Conclusion
The Court held that when police have probable cause to believe a readily mobile vehicle contains contraband, the Fourth Amendment permits a warrantless search without any additional showing that officers lacked time or opportunity to obtain a warrant.