## Facts

- Eugene H. Edwards was lawfully arrested in Lebanon, Ohio around 11 p.m. on suspicion of attempting to break into the local U.S. Post Office.
- Police had probable cause to believe Edwards’s clothing contained paint chips linked to the post-office window involved in the attempted break-in.
- Edwards was taken to the city jail and placed in a cell wearing his own clothes.
- Because substitute clothing was unavailable late at night, officers did not immediately take his clothing.
- The next morning, after providing replacement clothing, officers seized Edwards’s original clothing without a warrant and submitted it for laboratory analysis.
- Testing revealed paint chips on the clothing that matched paint from the post-office window.
- At Edwards’s federal trial for attempted breaking and entering of a U.S. Post Office, the court admitted the clothing and test results over a Fourth Amendment objection and convicted him.
- The Sixth Circuit reversed, holding the warrantless seizure about 10 hours after arrest was not a valid search incident to arrest because arrest-related administrative processes had ended.
- The Supreme Court granted certiorari.

## Issues

1. Whether the Fourth Amendment requires suppression of clothing seized without a warrant from a lawfully arrested person at a jail about 10 hours after arrest for evidentiary testing.
2. Whether a search incident to a lawful custodial arrest may be performed at the place of detention after a substantial time lapse when the item was within the scope of what could have been seized at the time of arrest.

## Decision

- The Supreme Court reversed the Sixth Circuit (5–4) and reinstated Edwards’s conviction.
- The Court held the warrantless seizure and subsequent examination of Edwards’s clothing did not violate the Fourth Amendment.
- The Court reasoned that items subject to search at the time and place of a lawful custodial arrest may be seized and searched later at the place of detention while the arrestee remains in custody.
- The Court found the delay reasonable because the normal processes incident to arrest and custody were still being completed, and substitute clothing was unavailable at the time of booking.
- A dissent argued that once arrest processing had ended, officers needed a warrant to seize items for evidence and that the ruling improperly extended the time period for warrantless searches incident to arrest.

## Legal Principles

- A lawful custodial arrest based on probable cause is a reasonable Fourth Amendment intrusion, and a search incident to that arrest requires no additional justification.
- Effects in an arrestee’s possession at the place of detention that were subject to search at the time and place of arrest may be searched and seized without a warrant even after a substantial time lapse, so long as the arrestee remains in custody.
- Administrative and practical constraints related to normal custody procedures can justify a brief delay in seizing an arrestee’s clothing and similar personal effects for evidentiary examination.

## Conclusion

The Court held that police may, without a warrant, seize and examine an arrestee’s clothing at the jail several hours after a lawful custodial arrest when the clothing could have been taken at arrest and the delay is reasonably tied to ordinary arrest and detention procedures.


United States v. Edwards, 415 U.S. 800 (1974)