United States v. Chadwick, et al.
Decided on June 21, 1977; 433 US 1


4th Amendment claims surface after agents' unwarranted
search of train passengers' carry-on foot locker


I. ISSUES II. CASE SUMMARY III. AMICI CURIAE IV. DECISION V. WIN OR LOSS?
I. ISSUES:

A. Issues Discussed: Criminal Justice (drugs), 4th Amendment

B. Legal Question Presented:

In accordance to the protections provided by the Fourth Amendment, what are the limitations of probable cause and when is it necessary to acquire a search warrant?

II. CASE SUMMARY:

A. Background:

On May 8, 1973, respondents Gregory Machado and Bridget Leary boarded an Amtrak train in San Diego, California heading to Boston, Massachusetts.  Respondents brought with them a large heavy brown footlocker which aroused suspicions among the Amtrak officials.  The officials reported the suspicious activities to the San Diego federal agents who in turn informed federal agents in Boston.

On arrival in Boston two days later, federal narcotics agents (petitioners) boarded respondents' train.  Although the agents did not obtain either an arrest or search warrant, they did keep respondents under surveillance, and directed a narcotics dog towards the footlocker without alerting the respondents.  The agents continued their surveillance after the dog signaled the presence of controlled substances within the locker.

Joseph Chadwick, a fellow respondent, joined Machado and Leary after they exited the train, and lifted the footlocker into his automobile.  Soon after all respondents entered the vehicle and before the engine was started, agents arrested all three.  A search of the respondents' bodies and their automobile revealed no weapons or contraband.

Respondents were then taken to the Federal Building for detention and processing along with the automobile and footlocker.  An hour and a half after the arrests, agents opened the footlocker and luggage without obtaining respondents’ consent or securing a search warrant,  and they found large amounts of marijuana.

The respondents were indicted for possession of marijuana with intent to distribute it.  Prior to the start of their trial, the District Court granted the respondents’ pretrial motion to suppress the evidence collected from the footlocker.  The Court of Appeals of the First Circuit affirmed the District Courts decision.

The US Supreme Court granted certiorari on appeal by the federal agents. 
B. Counsel of Record:
ACLU Side
(Respondent/Appellee)
Opposing Side
(Petitioner/Appellant)
Martin G. Weinberg argued the cause for respondents.  With him on the brief were Philip S. Nyman, Robert L. Steadman, and Jeanne Baker.
Deputy Solicitor General Randolph argued the cause for the United States.  On the brief were Acting Solicitor General Friedman, Assistant Attorney General Thornburgh, Kenneth S. Geller, and Sidney M. Glazer.
C. The Arguments:
ACLU Side
 
(Respondent/Appellee)
Opposing Side
(Petitioner/Appellant)
Unavialable Unavailable
III. AMICI CURIAE:
ACLU Side
(Respondent/Appellee)
Opposing Side
(Petitioner/Appellant)
Joel M. Gora, Jack D. Novik, and John Reinstein filed a brief for the American Civil Liberties Union et al. as amici curiae urging affirmance. Frank Carrington, Glen R. Murphy, Cecil Hicks, and James P. Costello filed a brief for Americans for Effective Law Enforcement, Inc., et al. as amici curiae.
IV. THE SUPREME COURT'S DECISION:

"[W]e do not agree that the Warrant Clause [Fourth Amendment] protects only dwellings and other specifically designated locales.  As we have noted before, the Fourth Amendment 'protects people, not places,' Katz v. United States, 389 U.S. 347 (1967); more particularly, it protects people from unreasonable government intrusions into their legitimate expectations of privacy.  In this case, the Warrant Clause makes a significant contribution to that protection…

[I]t would be a mistake to conclude, as the Government [petitioners] contends, that the Warrant clause was therefore intended to guard only against intrusions into the home.  First, the Warrant Clause does not in terms distinguish between searches conducted in private homes and other searches.  There is also a strong historical connection between the Warrant Clause and the initial clause of the Fourth Amendment, which draws no distinctions among 'persons, houses, papers, and effects' in safeguarding against unreasonable searches and seizures.

Moreover... the judicial warrant has a significant role to play in that it provides the detached scrutiny of a neutral magistrate, which is a more reliable safeguard against improper searches than the hurried judgment of a law enforcement officer…

In this case, important Fourth Amendment privacy interests were at stake.  By placing personal effects inside a double-locked footlocker, respondents manifested an expectation that the contents would remain free from public examination.  No less than one who locks the doors of his home against intruders, one who safeguards his personal possessions in this manner is due the protections of the Fourth Amendment Warrant Clause.  There being no exigency, it was unreasonable for the Government to conduct this search without the safeguards a judicial warrant provides.

Here the search was conducted more than an hour after federal agents had gained exclusive control of the footlocker and long after respondents were securely in custody; the search therefore cannot be viewed as incidental to the arrest or as justified by any other exigency.  Even though on this record the issuance of a warrant by a judicial officer was reasonably predictable, a line must be drawn…

[I]n our view, when  no exigency is shown to support the need for an immediate search, the Warrant Clause places the line at the point where the property to be searched comes under the exclusive dominion of police authority.  Respondents were therefore entitled to the protections of the Warrant Clause with the evaluation of a neutral magistrate, before their privacy interests in the contents of the footlocker were invaded.

Accordingly, the judgment [of the District Court and Court of Appeals] is affirmed."
Justice Vote: 7 Pro vs. 2 Con
  • Burger, W. Pro (Wrote majority opinion)
  • Stewart, P. Pro (Joined majority opinion)
  • Powell, L. Pro (Joined majority opinion)
  • Marshall, T. Pro (Joined majority opinion)
  • Stevens, J. Pro (Joined majority opinion)
  • White, B. Pro (Joined majority opinion)
  • Brennan, W. Pro (Wrote concurring opinion)
  • Blackmun, H. Con (Wrote dissenting opinion) 
  • Rehnquist, W. Con (Joined Blackmun’s dissent)
V. A WIN OR LOSS FOR THE ACLU?

The ACLU filed as amicus urging affirmance; The US Supreme Court affirmed the Court of Appeals decision in a 7-2 vote, giving the ACLU an apparent win.