Facts
- District of Columbia police received a tip from a previously reliable informant that a man known as “Bandit” was selling narcotics stored in the trunk of a car parked at a specified address.
- The informant described the suspect and a purplish maroon Chevrolet Malibu with D.C. plates.
- Officers went to the location, found a matching maroon Malibu, and learned it was registered to Albert Ross, who fit the description and used the alias “Bandit.”
- Officers observed the car being driven by a man matching the description, stopped the car, and ordered Ross out.
- An officer noticed a bullet on the front seat, searched the passenger compartment, and found a pistol in the glove compartment; Ross was arrested and handcuffed.
- Using Ross’s keys, an officer opened the trunk, found a closed brown paper bag, opened it, and discovered heroin.
- The car was later taken to headquarters, where officers conducted a more thorough warrantless trunk search and found a zippered red leather pouch containing $3,200.
- Ross was charged with possession of heroin with intent to distribute and moved to suppress the heroin and cash as the product of warrantless searches of closed containers.
Issues
- Whether probable cause to believe contraband is somewhere in an automobile permits a warrantless search of the vehicle that includes opening closed containers found inside.
- Whether the Fourth Amendment requires a warrant to open closed containers located in a vehicle’s trunk during an otherwise lawful automobile-exception search.
Decision
- The Supreme Court reversed the court of appeals and upheld admission of the heroin and cash.
- The Court held that when police have probable cause to search a vehicle, they may conduct a warrantless search as thorough as a warrant could authorize.
- That authority extends to closed containers found within the vehicle if the container could conceal the object of the search and is located where the probable cause justifies searching.
Legal Principles
- Under the automobile exception, a warrantless vehicle search supported by probable cause may extend to every part of the vehicle and its contents that may conceal the object of the search.
- The permissible scope of a search is determined by the object of the search and the places where there is probable cause to believe it may be found, not by the type of container encountered.
- Where probable cause is directed at the vehicle as a whole, officers may open containers within it that could hold the sought contraband without obtaining a separate warrant for each container.
- The scope of the warrantless search is limited to what a magistrate could have authorized in a warrant describing the place to be searched and the items to be seized.
Conclusion
The Court clarified that probable cause to search an automobile permits a warrantless search of the entire vehicle, including closed containers within it capable of hiding the object of the search, to the same extent a warrant would allow.