Quick Summary
Acevedo (the defendant) entered the apartment carrying a package that police suspected contained illegal substances. Acevedo placed the bag in the trunk of his car, and as he drove away, officers stopped him, searched the package, and discovered illegal marijuana.
Acevedo appealed not to allow the evidence as it was collected without a warrant. When there is probable cause, the Fourth Amendment says that a search warrant is not needed, and a vehicle can be searched.
After overturning the lower court’s decision to let marijuana be used as evidence, the California Supreme Court ordered a new trial.
Rule of Law
When probable cause exists, the Fourth Amendment does not require a warrant to examine a vehicle’s container. Instead, it’s defined by what’s being sought and where it may be located.
Facts of the Case
Acevedo (defendant) entered the apartment carrying a package that police suspected contained illegal substances. After a few minutes, he exited the apartment carrying the same package. Acevedo placed the bag in the trunk of his car, and as he drove away, officers stopped him, searched the package in the trunk, and discovered half a pound of marijuana.
Acevedo entered a guilty plea and filed an appeal after the trial court rejected his petition. The marijuana should have been excluded as evidence, the California Court of Appeal said, overturning the trial court’s decision.
The California Court of Appeals held that the marijuana found in the bag should have been suppressed at trial because the police needed a warrant to search the bag.
The court of appeals also found that the bag did not fall under the automobile exception since the police had probable cause that the bag, not the car, contained drugs. The United States Supreme Court granted certiorari.
Issue
Can police search a closed package in a car without a warrant if they have probable cause to believe it contains evidence?
Holding and Conclusion
Yes.
If there is probable cause, searching a vehicle’s storage compartment does not violate the Fourth Amendment.
The lower court’s judgment not to suppress evidence of marijuana was overturned, and the higher court ordered a new trial in accordance with its decision.
Reasoning and Analysis
The Fourth Amendment forbids the authorities from conducting any searches or seizures of a vehicle without a warrant. However, the U.S. Supreme Court has ruled that if police have probable cause, they can search for a person and belongings without a warrant.
Once the police have probable cause, they have the right to search the vehicle and remove anything from it that might be used to hide the item they are searching for. For example, let us say the police have reason to believe illegal substances are in a vehicle and discover a backpack inside. Police have the right to search any bag they suspect contains illegal substances, regardless of who the owner is (passenger or driver).
Relevant FAQs of this case
What is probable cause?
When an officer has knowledge of facts or context that would lead a reasonable person to suspect a crime has been or will be committed, they have probable cause to make an arrest.
The Fourth Amendment states:
“The right of the people to be secure in their persons, houses, papers, and effects, against unreasonable searches and seizures, shall not be violated, and no Warrants shall issue, but upon probable cause, supported by Oath or affirmation, and particularly describing the place to be searched, and the persons or things to be seized.”
What are the criteria of probable cause when derived from the information obtained by an informant?
The information provided by an informant must be legally guaranteed to be credible. Listed below are criteria that courts will use to determine the reliability of the evidence presented:
- Is the informant trustworthy?
In court, “integrity” determines if an informant has a history of telling the truth. Unlike anonymous tipsters, law enforcement and prosecutors have evidence that their informant misled or was honest with them. If the informant has been arrested for fraud or lying, their evidence may be rejected. - Where does the informant get his or her information?
The informant’s knowledge is rarely examined in court because they rarely testify. The court accepts the informant’s claims based on evidence. Unsupported facts or scenarios are not supported. - Informant reputation for reliability
If the informant consistently provides accurate information, the court may believe them.
References
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