Facts
- Police received a robbery report describing suspects and a getaway car.
- An officer stopped a car occupied by the petitioners after following it; the car differed from the reported vehicle’s color and license plate.
- The car’s owner was driving; the petitioners were passengers.
- Officers ordered the occupants out and searched the car.
- Police found rifle shells in the glove compartment and a sawed-off rifle under the front passenger seat.
- Petitioners were arrested and later convicted of armed robbery after the rifle and shells were admitted into evidence.
- Petitioners moved to suppress the items under the Fourth Amendment; state courts denied the motion on the ground that petitioners lacked “standing” because they neither owned the car nor claimed a possessory interest in the items seized.
Issues
- Whether automobile passengers who claim no property or possessory interest in the vehicle or items seized may challenge a search of the glove compartment and area under a seat under the Fourth Amendment.
- Whether “standing” should be treated as a separate threshold doctrine or as part of the substantive inquiry into whether the defendant’s own Fourth Amendment rights were violated.
Decision
- The Supreme Court affirmed the denial of suppression (5–4).
- The Court held petitioners could not challenge the search because they failed to show a legitimate expectation of privacy in the areas searched.
- The Court rejected a “target” theory that would allow defendants to object to searches merely because they were the focus of police investigation.
- The Court treated the “standing” question as part of the Fourth Amendment merits inquiry: whether the challenged search violated the defendant’s own Fourth Amendment rights.
- Because petitioners asserted no interest in the car or seized property and showed no expectation of privacy in the glove compartment or under-seat area, the exclusionary rule did not apply to them.
Legal Principles
- Fourth Amendment rights are personal and may not be asserted vicariously based solely on the use of evidence obtained from a search of another’s property.
- A defendant may seek suppression only by showing a legitimate (reasonable) expectation of privacy in the place searched.
- “Standing” is not an independent inquiry; it is resolved by determining whether the defendant’s own expectation of privacy was infringed.
- Lawful presence in a place (including being a passenger in a car) does not, by itself, establish an expectation of privacy in all compartments or areas of that place.
- Passengers who neither own nor possess the vehicle or seized items, and who show no privacy interest in the specific areas searched, generally cannot challenge the search of those areas.
Conclusion
The Court held that automobile passengers who do not claim an interest in the vehicle or seized items and who do not show a reasonable expectation of privacy in the specific areas searched cannot invoke the Fourth Amendment to suppress evidence found there, reframing “standing” as part of the substantive privacy inquiry.