California v. Acevedo
California v. Acevedo is a significant Supreme Court case that clarified the legal standards surrounding the search of vehicles and containers within them. Prior to this case, there was confusion stemming from previous rulings—specifically, United States v. Chadwick and United States v. Ross—about whether police needed a warrant to search containers found in vehicles. In Acevedo, police observed Charles Acevedo placing a bag into his car's trunk and, believing it contained marijuana, searched the bag without a warrant. California courts initially ruled that this search was unconstitutional, adhering to the precedent set by Chadwick.
However, the Supreme Court, in a 6-3 decision, reversed this ruling, establishing a clear rule that allowed police to search containers in vehicles without a warrant when they have probable cause. Justice Harry A. Blackmun, in the majority opinion, emphasized that the Fourth Amendment’s protections should not vary based on the specific circumstances of an automobile versus its contents. This decision has had lasting implications for law enforcement procedures and the interpretation of privacy rights under the Fourth Amendment, influencing how searches are conducted in similar contexts.
California v. Acevedo
Date: May 30, 1991
Citation: 500 U.S. 565
Issue: Automobile searches
Significance: The Supreme Court held that the police may search either an automobile or a closed container in an automobile without a search warrant provided that the search is supported by probable cause.
The Acevedo decision established “one clear-cut rule” for searches of both automobiles and containers within automobiles. After 1925 the Supreme Court had allowed the police to stop and search moving vehicles on probable cause without a search warrant. In United States v. Chadwick (1977), however, the Court held that the police needed a warrant to search a sealed container, even when the container was located in an automobile. Then in United States v. Ross (1982), the Court allowed the police to search any containers that happened to be located in an automobile that was being searched on the basis of probable cause. The combination of Chadwick and Ross often confused judges and the police.
When the police observed Charles Acevedo put a brown bag into the trunk of his car, they had probable cause to think that the bag contained marijuana. Although the police had no other justification to search the car, they nevertheless took the bag from the trunk and opened the bag without getting a warrant. California courts, in conformity with Chadwick, ruled that the marijuana in the bag could not be used as evidence in a criminal trial. By a 6-3 vote, however, the Supreme Court reversed the Chadwick ruling. Justice Harry A. Blackmun’s majority opinion argued that the Fourth Amendment’s protection of privacy should not depend on “coincidences” such as whether the probable cause referred to the automobile or to the container.