Chambers v. Maroney

Supreme Court of the United States · 1970 · Criminal Procedure

399 U.S. 42 (1970)

Updated July 27, 2026

Criminal ProcedureFourth AmendmentWarrantless automobile searchesProbable causeautomobile exceptionwarrantless searchstation house searchsearch incident to arrest

Facts

After a gas station robbery by two armed men, police received descriptions of the robbers and of a light blue compact station wagon carrying four men, including one wearing a green sweater and another associated with a trench coat. Within an hour, police stopped a matching station wagon with four occupants, including petitioner in a green sweater, arrested them, and took the car to the police station. At the station, police searched the car without a warrant and found revolvers, a glove containing coins, and cards belonging to a victim of an earlier robbery. Petitioner later challenged the admission of the car-seized evidence, along with ammunition seized from his home and his counsel's effectiveness at the second trial.

Issue

Whether the Fourth Amendment permits police, with probable cause to search an automobile stopped on the highway, to take the car to the station house and conduct a warrantless search there rather than search it immediately on the scene. Also, whether petitioner's remaining claims concerning ammunition seized from his home and ineffective assistance of counsel required reversal.

Rule

Where police have probable cause to search an automobile for particular articles, the Fourth Amendment permits either an immediate warrantless search of the car or seizure and holding of the car for that search; for constitutional purposes, there is no difference between seizing and holding the car before presenting probable cause to a magistrate and carrying out an immediate search without a warrant. A station-house search is permissible when the car could have been searched on the spot based on probable cause and vehicle mobility.

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

After an armed pharmacy robbery in Akron, officers received a radio report that the suspects fled in a gray hatchback with three occupants and that one suspect wore a red flannel jacket. Forty minutes later, police stopped a matching hatchback on a public road, arrested the occupants, drove the car to headquarters because heavy traffic made a roadside search dangerous, and searched it there without a warrant, finding cash and a handgun hidden under the console.

Is the warrantless station-house search of the hatchback most likely constitutional?

Explanation. The search is valid under the automobile exception. When officers have probable cause to believe a stopped automobile contains seizable evidence, there is no constitutional difference between searching it immediately and seizing and holding it for a later warrantless search at the station. The majority specifically said such a later search is not justified as incident to arrest, but it is reasonable if the car could have been searched on the spot based on probable cause and mobility.