California v. Minjares

Background

Police in Fremont, California stopped a car after a witness followed two armed robbers from a store and wrote down the license number. The driver was arrested and the car was towed to a city yard. Officers opened the trunk there and found a red tote bag containing clothes, three guns, and a roll of pennies linked to the store. At trial the evidence was admitted and the man was convicted of two counts of first-degree robbery and being armed; the California Supreme Court later reversed, ruling a warrant was required to open the container in the trunk.

Reasoning

The immediate question was whether the state court’s decision to suppress the tote-bag evidence should be paused while higher review is considered. The full Supreme Court denied the state’s request to stay the California ruling. Justice Rehnquist dissented from that denial and urged the Justices to re-evaluate the federal exclusionary rule—the rule that keeps evidence out of trials when it was obtained in violation of the Fourth Amendment. He emphasized the police acted on a recent, serious robbery and argued the officers had probable cause and acted in good faith while pursuing a second suspect.

Real world impact

Because the stay was denied, the California suppression decision stands for now and the seized evidence remains excluded in that case. Rehnquist warned that the exclusionary rule can free guilty defendants and suggested modern civil remedies and recent cases reduce the need for that rule; he would have granted a stay and asked for briefing on whether the rule should be retained.

Dissents or concurrances

Justice Rehnquist’s dissent, joined by the Chief Justice, pressed for reconsideration of long-standing cases (Weeks, Wolf, Mapp) and noted possible mootness if an acquittal occurs before full review.