Robbins v. California

Background

A man driving a station wagon was stopped for erratic driving. Officers smelled marijuana, found drugs and paraphernalia in the passenger area, and then opened a recessed luggage compartment. Inside they found two green, opaque-wrapped packages. When officers unwrapped those packages, each contained 15 pounds of marijuana. The driver was charged, convicted, and the state courts upheld the search; the Supreme Court agreed to review the question of whether sealed containers found in a car can be opened without a warrant.

Reasoning

The central question was whether police may open a closed, opaque container found during a lawful warrantless automobile search without first getting a warrant. The Court relied on earlier decisions and said a person who places items in a closed, opaque container reasonably expects privacy in the contents. Unless the container’s contents are plainly visible or otherwise obvious from the outside, officers must obtain a warrant to open it. The Court found the evidence did not show the packages openly announced their contents and held that opening them without a warrant violated the Fourth and Fourteenth Amendments. The judgment of the California Court of Appeal was reversed.

Real world impact

After this decision, officers generally must seek a warrant before unwrapping or opening sealed packages found during a lawful car search, unless the contents are in plain view or another exception clearly applies. That will affect how quickly officers can examine sealed items in trunks or luggage during traffic stops and may lead to more magistrate involvement and suppression hearings.

Dissents or concurrances

Justice Powell joined the judgment but urged a narrower rule, saying the careful sealing showed an expectation of privacy. Other Justices dissented, arguing the automobile exception should allow container searches when police have probable cause to search the car.