United States v. Robinson

414 U.S. 218 (1973).

One-Sentence Takeaway: A full search of the person following a lawful custodial arrest does not violate the Fourth Amendment.

Summary: An officer spotted Robinson driving a car and the officer had probable cause that Robinson was driving the car after the revocation of his license. Officer stopped Robinson and lawfully arrested him. Officer patted down the person of Robinson and felt a cigarette packet and he further searched the packet and found heroin capsules.

The issue presented to the United States Supreme Court was whether the search of Robinson was constitutional.  The Court held that the search was constitutional.

The Court reasoned that it is well established that a search incident to a lawful arrest is a traditional exception to the warrant requirement of the Fourth Amendment.  In Chimel v. California, the Court held that it was reasonable for the arresting officer to search the person arrested in order to remove any weapons that the arrestee might attempt to use in order to resist arrest or effect his escape.  Furthermore, the justification or reason for the authority to search incident to a lawful arrest rests quite as much on the need to disarm the suspect in order to take him into custody as it does on the need to preserve evidence on his person for later use at trial. Also, a custodial arrest of a suspect based on probable cause is a reasonable intrusion under the Fourth Amendment that intrusion being lawful, a search incident to arrest requires no additional justification.

Based on the foregoing, the Court held that a search of the arrestee incident to a lawful arrest is not only a valid exception to the warrant rule but it is also reasonable under the Fourth Amendment.

Related entries