Facts
- A Washington State University police officer stopped student Carl Overdahl after seeing him leave a dormitory carrying a bottle of gin and believing he was underage.
- The officer asked for identification; Overdahl said it was in his dorm room and the officer accompanied him there.
- While standing in the open doorway and monitoring Overdahl and his roommate, Chrisman, the officer observed what he believed were marijuana seeds and a pipe on a desk.
- The officer entered the room, confirmed the seeds were marijuana and the pipe smelled of marijuana, and administered Miranda warnings.
- When asked whether there were other drugs, Chrisman produced a box containing additional marijuana and cash.
- After another officer arrived, Overdahl and Chrisman gave oral and written consent to search the room, yielding more marijuana and another controlled substance.
- Chrisman was convicted of possessing controlled substances; state appellate courts affirmed, but the Washington Supreme Court reversed, finding the entry and seizure unlawful and the consent search tainted.
Issues
- Whether the Fourth Amendment permits an officer, after a lawful custodial arrest, to accompany and monitor the arrestee when the arrestee enters his residence to obtain identification, without a warrant or separate exigency.
- Whether contraband observed while the officer is lawfully present may be seized under the plain-view doctrine.
- Whether a subsequent consent search is invalid as fruit of an unlawful entry or seizure.
Decision
- The U.S. Supreme Court reversed the Washington Supreme Court.
- It held that, following a lawful custodial arrest, it is reasonable for an officer as a routine matter to accompany and monitor the arrestee’s movements, including into the arrestee’s room to retrieve identification.
- Because the officer was lawfully present while supervising the arrestee, the seizure of contraband in plain view did not violate the Fourth Amendment.
- With no Fourth Amendment violation in the initial entry or seizure, the subsequent consent search was not tainted and the evidence was admissible.
Legal Principles
- After a lawful custodial arrest, an officer may monitor the arrestee’s movements and may accompany the arrestee into a residence to maintain safety and the integrity of the arrest; no separate showing of exigent circumstances is required for that accompaniment.
- Under the plain-view doctrine, officers may seize clearly incriminating evidence without a warrant when it is observed from a location where the officer has a lawful right to be and has lawful access.
- A consent search is not suppressed as fruit of illegality when the predicate police conduct was lawful.
Conclusion
The Court upheld admission of drugs found in a dorm room because the officer’s accompaniment of the arrestee into the room was reasonable incident to a lawful custodial arrest, permitting seizure of contraband in plain view and eliminating any taint claim against the later consent search.