California v. Acevedo

Background

California police received word that a package of marijuana had been sent to a local Federal Express office and was claimed by someone identifying himself as Jamie Daza. Officers later saw Charles Acevedo carry a brown paper bag from Daza's apartment to his car and place it in the trunk. Police stopped Acevedo, opened the trunk and the bag, and found marijuana. Acevedo pleaded guilty after the trial court denied his motion to suppress; the California Court of Appeal ordered the evidence suppressed, finding probable cause only as to the bag.

Reasoning

The Supreme Court considered whether the Fourth Amendment requires a warrant to open a closed container found in an automobile when officers have probable cause to believe the container, but not the whole car, holds contraband. The majority held that the rule from Ross applies: if officers have probable cause to search a container in a car, they may open it without a warrant. The Court rejected the separate rule from Sanders that had protected luggage in trunks, saying that the difference created confusion and provided little privacy benefit. The state court judgment was reversed and the case remanded.

Real world impact

The decision allows police nationwide to search closed containers in vehicles without a warrant when they have probable cause specific to the container. It reduces the special privacy protection that once shielded luggage and similar items simply because they were in a car. The ruling was framed as a clarification of the automobile-search rules and was remanded for further proceedings.

Dissents or concurrances

Justice Stevens (joined by Justice Marshall) and Justice White dissented, warning the decision enlarges the automobile exception and weakens privacy; Justice Scalia concurred in the judgment for separate reasons.