United States v. Chadwick
United States v. Chadwick | |||||||
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Argued April 26, 1977 Decided June 21, 1977 | |||||||
Full case name | United States v. Chadwick et al. | ||||||
Citations | |||||||
Holding | |||||||
Absent exigency, the warrantless search of double-locked luggage just placed in the trunk of a parked vehicle is a violation of the Fourth Amendment and not justified under the automobile exception. | |||||||
Court membership | |||||||
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Case opinions | |||||||
Majority | Burger, joined by Brennan, Stewart, White, Marshall, Powell, Stevens | ||||||
Concurrence | Brennan | ||||||
Dissent | Blackmun, joined by Rehnquist | ||||||
Laws applied | |||||||
Fourth Amendment |
United States v. Chadwick, 433 U.S. 1 (1977), was a decision by the United States Supreme Court, which held that, absent exigency, the warrantless search of double-locked luggage just placed in the trunk of a parked vehicle is a violation of the Fourth Amendment and not justified under the automobile exception. The court reasoned that while luggage is movable like an automobile, it does not have the lesser expectation of privacy associated with an automobile.
Chadwick was later abrogated on other grounds by California v. Acevedo, 500 U.S. 565 (1991), in which the Supreme Court overruled Chadwick's holding with respect to containers within a vehicle, holding that police may search a container within a vehicle without a warrant if they have probable cause to believe that the container itself holds contraband or evidence.
Chadwick’s holding that a search incident to arrest must not be too remote in time or place is still good law.
Applications
- People v. Diaz 51 Cal. 4th 84, 244 P.3d 501, 119 Cal. Rptr. 3d 105 (2011)
See also
- List of United States Supreme Court cases, volume 433
- Carroll v. United States, 267 U.S. 132 (1925)
- Arkansas v. Sanders, 442 U.S. 753 (1979)
- United States v. Ross, 456 U.S. 798 (1982)
- California v. Greenwood, 486 U.S. 35 (1988)