Rawlings v. Kentucky

Background

A man visiting a house in Bowling Green was charged after police executing a warrant for another person searched the home. Officers smelled marijuana, left to get a warrant, and detained the occupants about 45 minutes. When the officers returned, a woman emptied her purse and 1,800 LSD tablets and other pills fell out. She told the visitor to "take what was his," and he claimed the drugs. Officers searched him, found $4,500 and a knife, and then arrested him. The visitor said he had earlier put the drugs in her purse; the woman gave a different version.

Reasoning

The Court addressed whether the visitor had a reasonable privacy interest in the purse, whether his admission was tainted by the detention, and whether the search of his person was lawful. Applying the Court's privacy-expectation approach, the majority found no legitimate expectation because of the brief transfer and others' access to the purse. Considering prior factors on voluntariness, the Court found the admission voluntary: he received Miranda warnings, the detention was short and described as congenial, and his statement came immediately when the drugs were shown. Once he admitted ownership, officers had probable cause, and the search of his person was lawful as incident to arrest. The Court therefore affirmed the conviction.

Real world impact

The ruling permits evidence from another person's bag to be used against someone who lacks a genuine privacy expectation. Short detentions to obtain a warrant do not automatically bar later admissions if warnings and circumstances show voluntariness. Searches near the time of arrest may be upheld when officers have probable cause.

Dissents or concurrances

One justice would have sent the case back to the state court for more factual work; two justices dissented, arguing ownership of seized items should allow exclusion of the evidence.