## Facts

- Federal narcotics agents surveilled respondents arriving by train in Boston from San Diego with a roughly 200-pound, double-locked footlocker.
- Agents developed probable cause to believe the footlocker contained marijuana, including information from investigation and a trained dog’s reaction.
- Respondents placed the footlocker into the trunk of a waiting car; agents then arrested them and seized the footlocker.
- Agents transported respondents and the footlocker to a federal building.
- About 90 minutes after the arrests, with the footlocker in law enforcement’s exclusive control, agents opened it without a warrant, consent, or any emergency circumstances and found large quantities of marijuana.
- The district court suppressed the marijuana; the court of appeals affirmed.

## Issues

1. Whether the Fourth Amendment permits a warrantless search of a locked footlocker supported by probable cause after the footlocker has been seized and is securely in exclusive police control, absent exigent circumstances.
2. Whether the search was valid as a search incident to arrest despite occurring later and at a different location from the arrest.
3. Whether the automobile exception justified opening the footlocker because it had been placed in a car trunk.

## Decision

- The Supreme Court affirmed suppression of the evidence.
- The warrantless search violated the Fourth Amendment because no exigent circumstances justified opening the locked footlocker once it was secured in exclusive police custody.
- The search was not a valid search incident to arrest because it was too remote in time and place from the arrest and the container was not within the arrestees’ immediate control.
- The automobile exception did not apply where the container was seized and searched after being removed to a secure location and the rationales for automobile searches were absent.

## Legal Principles

- Warrantless searches are presumptively unreasonable under the Fourth Amendment unless they fall within a specifically established exception.
- A person has a substantial expectation of privacy in the contents of locked personal luggage; seizure of a container is distinct from the greater intrusion of opening it.
- The search-incident-to-arrest exception is limited to searches substantially contemporaneous with the arrest and confined to the immediate vicinity, justified by officer safety and preservation of evidence within the arrestee’s reach.
- When a container seized incident to arrest is no longer accessible to the arrestee and there is no risk of removal or destruction of its contents, police must obtain a warrant to search it unless another exception (such as exigency) applies.
- The automobile exception does not automatically extend to locked luggage merely because it was placed in a vehicle, particularly when the search occurs after the container is secured and immobilized in police custody.

## Conclusion

The Court held that, absent exigent circumstances, officers who lawfully seize a locked footlocker supported by probable cause must obtain a warrant before opening it once the footlocker is under exclusive police control, and that neither the search-incident-to-arrest doctrine nor the automobile exception justified the delayed, off-site search.


United States v. Chadwick, 433 U.S. 1 (1977)