United States v. Chadwick

Supreme Court of the United States · 1977 · Criminal Procedure

433 U.S. 1 (1977)

Updated July 27, 2026

Criminal ProcedureFourth AmendmentSearch and SeizureWarrant RequirementSearch Incident to ArrestAutomobile Exceptionlocked footlockerluggage

Facts

Federal agents in Boston had probable cause to believe a double-locked 200-pound footlocker arriving by train contained contraband after receiving information from San Diego officials and using a trained dog. They arrested respondents after the footlocker was loaded into the open trunk of a car, seized the footlocker, and took it with respondents to the Federal Building. From the moment of arrest onward, the footlocker remained under the exclusive control of law enforcement, there was no risk of removal by respondents or associates, and the agents had no reason to think it contained dangerous items or evidence requiring immediate opening. About an hour and a half after the arrest, agents opened the locked footlocker without consent and without a warrant and found marijuana.

Issue

Whether federal agents may, without a warrant, open a locked footlocker they lawfully seized at the time of arrest when they have probable cause to believe it contains contraband, after the footlocker has been reduced to their exclusive control and no exigency exists.

Rule

The Fourth Amendment Warrant Clause applies to personal luggage and effects outside the home. Once law enforcement officers have reduced luggage or other personal property not immediately associated with the person of the arrestee to their exclusive control, and there is no longer any danger that the arrestee might gain access to the property to seize a weapon or destroy evidence, a warrantless search of that property is not justified as incident to arrest; absent exigent circumstances, a warrant is required.

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

DEA agents in Philadelphia lawfully arrested Nolan Pierce outside a bus terminal after developing probable cause that his locked roller suitcase contained cocaine. They seized the suitcase, took Nolan to a secure federal office, and opened the suitcase 90 minutes later without consent or a warrant; throughout that time the suitcase remained in exclusive police custody, and agents had no reason to think it contained anything dangerous or perishable evidence.

Is the warrantless search of the suitcase most likely constitutional?

Explanation. The majority rule is that personal luggage retains substantial Fourth Amendment protection. When officers have reduced luggage or other personal property not immediately associated with the arrestee's person to their exclusive control, and there is no longer any danger that the arrestee can gain access to a weapon or destroy evidence, a warrantless search is not justified as incident to arrest. Probable cause and lawful seizure alone do not authorize opening the locked suitcase.