Cady v. Dombrowski

Supreme Court of the United States · 1973 · Criminal Law

Criminal LawFourth AmendmentAutomobile searchesFourth Amendmentwarrantless searchautomobilecommunity caretakingplain view

Facts

Respondent, a Chicago police officer, crashed a rented 1967 Thunderbird in Wisconsin while intoxicated, and local officers had the disabled car towed to a private garage because respondent could not arrange for it himself. Believing Chicago officers were required to carry service revolvers and not finding one on respondent's person or in the passenger area, Officer Weiss later went to the garage as part of what the state courts found to be standard procedure to locate the gun and protect the public. In the car and locked trunk he found bloodstained items later used in respondent's murder trial. Police also later searched respondent's disabled 1960 Dodge under a valid warrant and seized additional bloody items, including a sock and floor mat not listed in the warrant return.

Issue

Whether the warrantless search of the trunk of the 1967 Thunderbird was unreasonable under the Fourth and Fourteenth Amendments because no warrant had been obtained, and whether the sock and floor mat taken from the 1960 Dodge were unconstitutionally seized.

Rule

The ultimate Fourth Amendment standard is reasonableness. A warrantless caretaking search of an automobile is not unreasonable solely because officers did not obtain a warrant when the vehicle has been lawfully taken under police control, is vulnerable to intrusion, and officers reasonably believe it contains a firearm that could endanger the public; items discovered in plain view during execution of a valid warrant may be seized even if not specifically listed, and omission from the warrant return is not constitutionally significant.

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One of 10 multiple-choice questions for this case. Pick an answer to see why.

In rural Montana, Deputy Erin Solis responded to a rollover outside Billings. The driver, Nolan Pierce, was unconscious and taken to a hospital, and his pickup was towed at police direction to an unsecured repair yard. After learning Nolan was a county corrections officer and reasonably believing his duty pistol was missing, Erin opened the locked truck bed cover without a warrant to secure the weapon and saw bloodstained tools inside.

Are the bloodstained tools likely admissible under the Fourth Amendment?

Explanation. The majority held that the ultimate Fourth Amendment standard is reasonableness, and that a warrantless search of a vehicle under police control may be valid when officers reasonably believe it contains a gun that could endanger the public if the unattended vehicle is vulnerable to intrusion. Here, the vehicle was lawfully towed, outside the owner's custody, left in an unsecured place, and the officer acted to locate a missing service weapon rather than to gather evidence. Under that reasoning, incriminating items discovered during that caretaking search are admissible.