## Facts

- A Washington, D.C. police officer had prior knowledge that Willie Robinson, Jr.’s operator’s permit had been revoked.
- The officer observed Robinson driving, stopped him, and made a full-custody arrest for driving while his license was revoked.
- Following standard procedures, the officer conducted a complete search of Robinson’s person incident to the arrest.
- The officer felt an object in Robinson’s coat pocket, removed a crumpled cigarette package, and opened it.
- Inside the package were 14 gelatin capsules later identified as heroin.
- Robinson was federally prosecuted and convicted for possession and facilitation of concealment of heroin; the heroin was admitted into evidence.
- The court of appeals reversed on Fourth Amendment grounds, concluding the search incident to a traffic arrest was impermissibly broad.

## Issues

1. Whether the Fourth Amendment permits a full search of an arrestee’s person, including opening a container found on the person, incident to a lawful custodial arrest without additional justification.
2. Whether the permissibility of such a search depends on the arresting officer’s subjective fear, suspicion, or case-specific likelihood of finding weapons or evidence.

## Decision

- The Supreme Court reversed the court of appeals and reinstated Robinson’s conviction.
- The Court held that, following a lawful custodial arrest supported by probable cause, a full search of the arrestee’s person is both an exception to the warrant requirement and reasonable under the Fourth Amendment.
- The Court upheld the search of the cigarette package and the admission of the heroin.
- The Court rejected a case-by-case requirement to show particularized reasons (such as a specific risk of weapons or a likelihood of evidence) for searching the person after a lawful custodial arrest.
- The Court distinguished limited stop-and-frisk searches based on reasonable suspicion from the broader authority that accompanies a full custodial arrest.

## Legal Principles

- A lawful custodial arrest based on probable cause automatically authorizes a full search of the arrestee’s person incident to arrest.
- The authority to search incident to arrest does not depend on the nature of the offense of arrest, including minor traffic offenses.
- The search-incident-to-arrest doctrine permits inspection of items and containers found on the arrestee’s person as part of the arrestee’s “immediate effects.”
- The reasonableness of a search incident to arrest does not turn on the officer’s subjective fear or individualized suspicion that weapons or evidence will be found.
- A search incident to arrest is broader than a protective frisk under reasonable suspicion and is not limited to a patdown for weapons.

## Conclusion

The Court held that once police make a lawful custodial arrest supported by probable cause, the Fourth Amendment allows a full search of the arrestee’s person and containers found on the person without further case-specific justification, making the heroin discovered in Robinson’s pocket admissible.


United States v. Robinson, 414 U.S. 218 (1973)