Carroll v. United States
Carroll v. United States is a landmark Supreme Court case that addresses the search and seizure of automobiles under the Fourth Amendment. The case originated when federal agents suspected George Carroll was transporting illegal liquor in his car. After pursuing him, they conducted a warrantless search and discovered concealed bottles of liquor, leading to his conviction. Carroll's defense argued that the search violated his Fourth Amendment rights, which protect against unreasonable searches and seizures.
The Supreme Court, in a 6-2 decision, upheld the conviction, with Chief Justice William H. Taft articulating a crucial distinction between stationary properties and vehicles. The Court recognized the inherent mobility of automobiles and established the "automobile exception," allowing warrantless searches if there is probable cause to believe they contain contraband. This ruling has had lasting implications for law enforcement practices and has prompted ongoing discussions about the balance between individual rights and public safety, particularly as it pertains to the limits of the automobile exception in subsequent cases.
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Carroll v. United States
Date: March 2, 1925
Citation: 267 U.S. 132
Issue: Automobile searches
Significance: The Supreme Court held that the Fourth Amendment permits the police to stop and search a vehicle without a warrant when there is probable cause that it contains illegal contraband.
Based on a combination of circumstances, federal agents had reason to think that George Carroll was illegally transporting liquor in his automobile. Following a chase, the agents searched his automobile without a warrant and found bottles of liquor concealed in the back seat. After Carroll’s conviction, his lawyers argued that the evidence should have been excluded from his trial because it violated the requirements of the Fourth Amendment.
By a 6-2 margin, the Supreme Court rejected the claim. Speaking for the majority, Chief Justice William H. Taft wrote that the US legal tradition had long accepted a distinction between stationary buildings and means of transportation such as boats or automobiles, in which mobility often made it impractical for the police to secure a warrant. At the same time, Taft insisted that the Fourth Amendment prohibited all “unreasonable searches and seizures.” Trying to reconcile these two considerations, he wrote that the police must not stop and search highway travelers unless there is probable cause that the vehicles are carrying contraband.
Carroll’s so-called “automobile exception” is well established. Since the 1970s, however, the Court had to decide many difficult questions about the implications and limits of the decision. In California v. Carney (1985), for example, the Court held that a motor home, unless situated in a residential location, falls under the Carroll ruling.
Bibliography
"Carroll v. US." FindLaw. Thomson, n.d. Web. 7 Jan. 2016.
Del Carmen, Rolando V. "Carroll v. United States." Criminal Procedure and the Supreme Court: A Guide to the Major Decisions on Search and Seizure, Privacy, and Individual Rights. Ed. Rolando V. Del Carmen and Craig Hemmens. Lanham: Rowman, 2010. 187–201. Print.
Vile, John R. "Carroll v. United States (1925)." Encyclopedia of the Fourth Amendment. Ed. John R. Vile and David L. Hudson, Jr. Thousand Oaks: SAGE, 2013. 156–57. Print.