One 1958 Plymouth Sedan v. Pennsylvania

Background

Two Pennsylvania Liquor Control Board officers watched a 1958 Plymouth sedan with Pennsylvania plates driving toward Philadelphia, followed it across the Benjamin Franklin Bridge, stopped the car, identified themselves, and searched it. They found 31 cases of liquor without Pennsylvania tax seals, seized the car and liquor, and arrested the owner, George McGonigle. The officers had no search or arrest warrant. Pennsylvania filed a petition to forfeit the automobile under state law.

Reasoning

The trial court dismissed the forfeiture because it found the search lacked probable cause and the evidence was illegally obtained. Pennsylvania’s higher courts reversed, saying the rule that bars illegally seized evidence applies only in criminal trials, not civil forfeitures. The Supreme Court disagreed. It relied on earlier decisions holding that forfeiture actions are quasi-criminal and that courts may not use evidence obtained in violation of the Constitution. The Court therefore held that the rule barring illegally seized evidence applies in forfeiture proceedings, reversed the Pennsylvania Supreme Court, and sent the case back so the state courts can reconsider whether the officers had probable cause.

Real world impact

The ruling means states generally cannot use evidence from unlawful searches to take people’s property in forfeiture cases. Owners whose property was seized without proper cause can seek review in state court. The decision affects how police and state agencies handle seizures and evidence in similar enforcement actions.

Dissents or concurrances

Justice Black concurred, agreeing with the result but stressing the connection between the Fourth and Fifth Amendments as the basis for excluding compelled or illegally obtained evidence.