California v. Acevedo

500 U.S. 565 (1991)

One-Sentence Takeaway: Police can conduct warrantless search of a container in a vehicle if there is probable cause to search that specific container, even if the officers lack probable cause to search the entire vehicle.

Facts: The DEA seized a package containing marijuana at the Federal Express Office in Hawaii.  That package was addressed to one J.R. Daza (“Daza”) and was to be delivered to the Federal Express Office in Santa Ana.  The DEA coordinated an investigation with the Santa Ana police.

The Santa Ana Police officers observed Daza picking up the package from the Federal Express Office and driving it to his home.  Later, the officers observed Charles Steven Acevedo (“Defendant”) entering Daza’s house and walking out with a package that looked similar to the one Daza had picked up with the marijuana.  Defendant placed the package in the truck of his vehicle and drove away.

The officers stopped Defendant and searched the package in the trunk and found marijuana.

Issue(s) Presented:  The issue presented to the Court was whether the officers could conduct warrantless search of the package in Defendant’s car when they lacked probable cause to conduct a general search of the entire car.

Holding: The Court held that, as long as the officers had probable cause to search the specific package in the car, they could conduct a warrantless search of that package even if they lacked probable cause to search the entire vehicle.  The Court reasoned:

“In the case before us, the police had probable cause to believe that the paper bag in the automobile’s trunk contained marijuana.  That probable cause now allows a warrantless search of the paper bag.  The facts in the record reveal that the police did not have probable cause to believe that contraband was hidden in any other part of the automobile and a search of the entire vehicle would have been without probable cause and unreasonable under the Fourth Amendment . . . The police may search an automobile and the containers within it where they have probable cause to believe contraband or evidence is contained.”

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