Preston v. United States
Headline: Court reverses conviction, rules police search of a parked car at a garage after suspects were arrested was unconstitutional, blocking key car-based evidence in the case.
Holding: The warrantless search of a car at a garage after the suspects were arrested and taken to the station was not incident to the arrest and was therefore an unreasonable search under the Fourth Amendment, making the evidence inadmissible.
- Blocks use of evidence from warrantless car searches made after suspects are detained.
- Limits police power to search vehicles once suspects are in custody and the vehicle is secured.
- May lead courts to exclude items found in delayed, unwarranted vehicle searches.
Summary
Background
A man and three companions were stopped by Newport, Kentucky, police after a late-night tip about suspicious men sitting in a parked car. The officers arrested the three on a vagrancy charge, took them to the station, and had the car towed to a garage. Later, officers searched the car at the garage and found guns and items like caps, stockings with holes, rope, pillow slips, and a snap-on license plate. After that search, one companion confessed about an intended bank robbery, the FBI was called, and federal charges followed. The conviction rested largely on items taken from the car.
Reasoning
The Court considered whether the later, warrantless search of the car was reasonable. It explained that police may search a person and the area immediately within the person’s control when making a lawful arrest to find weapons or prevent destruction of evidence. But once the suspects were in custody at the station and the car was in police custody at a garage, there was no realistic danger of the suspects getting weapons, fleeing, or destroying evidence. Because the search happened later and at another place, it was not properly “incident to arrest” and so was unreasonable under the protection against unreasonable searches.
Real world impact
As a result, the Court held the car search evidence inadmissible and reversed the conviction. That means evidence taken from a vehicle after suspects are detained and the vehicle is secured may not be used if no warrant justified that later search. The Court did not decide whether the original arrests were valid; it rested its decision on the timing and place of the search.
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