United States v. Edwards

Background

A man was arrested just after 11 p.m. in Lebanon, Ohio, for allegedly trying to break into the local post office. Police found paint chips at the scene that matched the window and screen. He was held overnight in the city jail; the next morning substitute clothes were bought, his clothing was taken, and lab tests later found paint chips matching the crime scene. At trial the clothing and test results were admitted over his objection, and a federal appeals court ruled that taking the clothes without a warrant after booking was unconstitutional.

Reasoning

The Supreme Court asked whether the Fourth Amendment bars taking and testing an arrestee’s clothing hours after arrest while the person is in custody. The majority said no. It relied on the rule that searches incident to a lawful custodial arrest are allowed and explained that items that could have been searched at arrest may reasonably be taken later at the place of detention. Because the clothing was already in police custody and probable cause linked it to the crime, the Court held the seizure and later laboratory testing were reasonable.

Real world impact

The decision lets police seize and preserve personal effects held in custody and use delayed testing as trial evidence when probable cause exists. The Court did not rule that warrants are never required for all post-arrest seizures, but it treated reasonable delays and routine processing as permissible in similar circumstances.

Dissents or concurrances

A dissent argued the seizure occurred about ten hours after arrest, was not contemporaneous, and so required a warrant; the dissent warned against eroding the warrant requirement.