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Carroll v. United States

Supreme Court of the United States · 1925 · Criminal Procedure

Criminal ProcedureFourth Amendmentautomobile exceptionprobable causewarrantless searchFourth Amendmentunreasonable searches and seizuresautomobile exception

Facts

Federal prohibition agents knew from prior dealings that the defendants were engaged in unlawful liquor traffic in Grand Rapids and had previously attempted to sell whisky to the agents. Later, while patrolling the highway from Detroit toward Grand Rapids, the agents saw defendants traveling west in the same automobile previously associated with their liquor activity. The agents stopped the car without a warrant, searched it, and found concealed intoxicating liquor in the seat back. The liquor was seized and used as evidence against defendants at trial for illegal transportation of liquor.

Issue

Whether officers may, without a warrant, stop and search an automobile for contraband liquor under the Fourth Amendment when the vehicle is being used on a public highway and the officers have probable cause to believe it is carrying liquor illegally. Also, whether the validity of the seizure depends on the lawfulness of an arrest for a misdemeanor without a warrant.

Rule

A warrantless search and seizure of an automobile or other vehicle is valid under the Fourth Amendment when officers have probable cause, meaning facts and circumstances known to them that would warrant a person of reasonable caution in believing the vehicle contains contraband or other property subject by law to seizure and destruction. Because vehicles are readily movable, a warrant is not required when obtaining one is not reasonably practicable, but officers may not stop and search every automobile at random; there must be probable cause directed to the particular vehicle. The validity of the search and seizure does not depend on the right to arrest, but on the officer's reasonable cause to believe the vehicle's contents violate the law.

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

In western Ohio, federal liquor agents station themselves on a public highway leaving Toledo because illegal liquor sometimes moves inland from the border region. Without any tip or prior knowledge about any particular driver, they stop every blue sedan for inspection; one of the stopped cars belongs to Nina Patel, and hidden bottles of contraband liquor are found in the trunk.

Is the warrantless search of Nina's car most likely constitutional under the governing rule?

Explanation. The majority drew a sharp line between permissible warrantless vehicle searches based on probable cause and intolerable random stops of travelers on public highways. Mobility alone does not authorize stopping every car on the chance of finding contraband. The search's validity turns on probable cause to believe the particular vehicle contains contraband, not on generalized enforcement concerns or arrest doctrine.