Harris v. United States

Background

A man was charged with robbing someone in Washington, D.C. Police traced and arrested him as he tried to enter his car. The car was towed to a police lot an hour after the arrest. Rain had started and the windows were open. An officer went to the lot, opened doors to roll up windows and secure the vehicle under a departmental rule that requires officers to protect impounded cars. When the officer opened a passenger door to secure it, he saw the victim’s registration card lying face up and took it to the station. At trial the defendant moved to exclude the card. He was convicted and sentenced. A court of appeals panel reversed, but the full court reinstated the conviction. The Supreme Court agreed to review the Fourth Amendment question.

Reasoning

The Court asked whether the officer’s action was an illegal search. It found that the officer lawfully opened the door to protect an impounded car and that the card was in plain view. The Court said the discovery resulted from protecting property, not an unlawful search, and noted the long-settled rule that officers may seize items plainly visible from a position they lawfully occupy. The Court therefore held no warrant was required in these narrow circumstances and affirmed the conviction.

Real world impact

The decision permits police who are securing impounded vehicles to seize plainly visible incriminating items without a warrant when the opening of the vehicle is lawful. It does not resolve whether broader routine inventories or other departmental searches are always permissible. The ruling is narrow and tied to protecting property in police custody.

Dissents or concurrances

Justice Douglas, in a short concurrence, emphasized that the car was lawfully in custody and officers discovered evidence while performing their duty to protect it.