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United States v. Place

Supreme Court of the United States · 1983 · Criminal Procedure

Criminal ProcedureFourth Amendmentdog sniffluggageTerry stopreasonable suspicioninvestigative detentionpersonal luggage

Facts

Miami agents became suspicious of Place at the airport, noted discrepancies in the addresses and phone number associated with his luggage, and relayed their information to DEA agents in New York. After Place arrived at La Guardia, DEA agents approached him, received his identification and ticket receipt, and, when he refused consent to search, told him they would take his bags to a federal judge to seek a warrant; they then took the bags from him. The agents transported the bags to Kennedy Airport and subjected them to a trained narcotics detection dog's sniff test, which occurred about 90 minutes after the seizure. The dog reacted positively to the smaller bag, and agents later obtained a warrant and found cocaine inside.

Issue

Does the Fourth Amendment permit law enforcement officers, on reasonable suspicion rather than probable cause, to briefly detain a traveler's luggage for exposure to a trained narcotics detection dog? If so, did the detention of Place's luggage remain within the permissible limits of such an investigative detention?

Rule

When an officer reasonably believes, based on specific and articulable facts, that a traveler is carrying luggage containing narcotics, Terry principles permit a brief detention of the luggage to investigate the suspicion, provided the detention is properly limited in scope. In assessing reasonableness, courts balance the nature and quality of the intrusion on Fourth Amendment interests against the governmental interests involved, considering especially the brevity of the detention and whether police diligently pursued the investigation. A trained canine sniff of luggage located in a public place is not a search under the Fourth Amendment because it is limited in manner and reveals only the presence or absence of narcotics.

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

At Denver International Airport, narcotics officers observe Omar Vega buy a one-way ticket with cash, give inconsistent answers about his destination, and check a hard-shell suitcase with a tag bearing a false callback number. As Omar walks through the public concourse with the suitcase, officers tell him they suspect narcotics, keep the suitcase next to him for about five minutes, and immediately have a trained detection dog sniff it there in the terminal.

Assuming the officers had specific and articulable facts supporting reasonable suspicion, which is the best Fourth Amendment analysis?

Explanation. The majority held that Terry principles can justify a brief detention of personal luggage based on specific and articulable facts creating reasonable suspicion that the luggage contains narcotics, so long as the detention is properly limited in scope. It also held that a trained canine sniff of luggage in a public place is not a search because it is limited in manner and reveals only the presence or absence of narcotics. A brief on-the-spot detention like this is the kind of minimal intrusion the Court described as potentially reasonable.