Pennsylvania v. Labron

Supreme Court of the United States · 1996 · Federal Courts

Federal CourtsFourth AmendmentAutomobile ExceptionSupreme Court Jurisdictionautomobile exceptionwarrantless searchprobable causeready mobility

Facts

In Labron, police observed Labron and others engaging in a series of street drug transactions in Philadelphia. After arresting the suspects, police searched the trunk of a car from which the drugs had been produced and found bags containing cocaine. In Kilgore, an informant arranged a drug purchase, police observed conduct linking Randy Kilgore and his pickup truck to the drug delivery, and after the arrests officers searched the truck parked in a farmhouse driveway and found cocaine on the floor. The state courts found probable cause existed in both cases but suppressed the evidence because no exigent circumstances justified a warrantless search.

Issue

Does the Fourth Amendment require police to obtain a warrant before searching an automobile unless exigent circumstances are present, even when the vehicle is readily mobile and police have probable cause to believe it contains contraband? Also, in Labron, did the Supreme Court have jurisdiction if the state court opinion allegedly rested on an adequate and independent state ground?

Rule

If a car is readily mobile and probable cause exists to believe it contains contraband, the Fourth Amendment permits police to search the vehicle without more. A state-court opinion does not bar Supreme Court review on adequate-and-independent-state-grounds principles unless it contains a plain statement making clear that federal law is used only for guidance and does not compel the result.

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

In Phoenix, officers watched Dana Morrow place several brick-shaped packages into the trunk of her sedan after a hand-to-hand exchange that appeared to be a drug sale. They arrested her moments later and searched the trunk on the street without first seeking a warrant, even though a magistrate was available nearby.

Under the majority rule, is the warrantless trunk search constitutional?

Explanation. The governing rule is that if a car is readily mobile and probable cause exists to believe it contains contraband, the Fourth Amendment permits a warrantless search of the vehicle without more. The majority rejected any separate requirement that police also show additional exigent circumstances such as lack of time to get a warrant. (Derived from Pennsylvania v. Labron (n.d.).)