Rawlings v. Kentucky

Supreme Court of the United States · 1980 · Criminal Procedure

448 U.S. 98 (1980)

Updated July 27, 2026

Criminal ProcedureFourth AmendmentSearch and SeizureExclusionary RulestandingRakasprivacy expectationfruit of the poisonous tree

Facts

Police entered a house with an arrest warrant for another person, smelled marihuana smoke, saw marihuana seeds, and detained the occupants while officers obtained a search warrant for the house. When officers returned with the warrant and read it along with Miranda warnings, Vanessa Cox was ordered to empty her purse, revealing LSD and other controlled substances that petitioner had earlier placed there. Cox told petitioner to take what was his, and petitioner immediately admitted the drugs were his; officers then searched his person, found cash and a knife, and formally arrested him. At the suppression hearing, petitioner testified he had put the drugs into Cox's purse and had asked her to carry them for him.

Issue

Whether petitioner could challenge the search of Cox's purse based on a legitimate expectation of privacy in it; whether his admission of ownership was the tainted fruit of an allegedly illegal detention; and whether the search of his person was lawful when it occurred just before his formal arrest.

Rule

A defendant may challenge a search only by showing that the government invaded his own legitimate expectation of privacy in the place searched; ownership of seized property alone does not control that inquiry. Even if a detention is illegal, a statement is admissible if, under Brown v. Illinois, it is an act of free will unaffected by the illegality, considering voluntariness, Miranda warnings, temporal proximity, intervening circumstances, and the purpose and flagrancy of the misconduct. A search of the person is valid as incident to arrest when probable cause to arrest already exists and the formal arrest follows quickly after the search.

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

In Phoenix, Nolan Price visited his friend Erin Cole's apartment for the first time. When sirens sounded outside, Nolan slipped several packets of cocaine into Erin's backpack, which she kept by the door, and told her to hold them for a minute. Officers later searched the apartment under a valid premises warrant and found the packets in Erin's backpack.

If Nolan is prosecuted for possessing the cocaine, is he most likely entitled to suppress the packets based on the search of Erin's backpack?

Explanation. The controlling rule is that a defendant may challenge a search only if the government invaded the defendant's own legitimate expectation of privacy in the place searched. Ownership of the seized drugs is relevant but not controlling. Here Nolan had only a sudden transfer of his drugs into Erin's backpack, had no prior access to it, and no apparent right to control it. Under the majority's reasoning, those facts do not show a legitimate expectation of privacy in the backpack itself.