United States v. Ross

Supreme Court of the United States · 1982 · Criminal Procedure

456 U.S. 798 (1982)

Updated July 27, 2026

Criminal ProcedureFourth AmendmentAutomobile exceptionWarrantless searchesprobable causewarrantless searchcontainersvehicle search

Facts

A reliable informant told Detective Marcum that a man known as "Bandit" was selling narcotics kept in the trunk of a purplish maroon Chevrolet Malibu parked at 439 Ridge Street and had just observed a sale. Officers verified that the car was Ross's, that Ross fit the description and used the alias "Bandit," then stopped the car after seeing Ross drive it away. After finding a bullet on the front seat and a pistol in the glove compartment, officers arrested Ross, opened the trunk with his keys, and found a closed brown paper bag containing glassine bags of white powder; later at the station they also found and opened a zippered red leather pouch containing $3,200. No warrant was obtained, and the powder was later identified as heroin.

Issue

When police lawfully stop an automobile and have probable cause to believe contraband is concealed somewhere within it, may they, without a warrant, open closed containers found inside the vehicle that might conceal the object of the search? More specifically, is the permissible scope of the automobile exception limited by the nature of the container or by the object of the search and the places probable cause extends to?

Rule

The scope of a warrantless automobile search based on probable cause is no broader and no narrower than a magistrate could authorize by warrant. If probable cause justifies the search of a lawfully stopped vehicle, it justifies the search of every part of the vehicle and its contents that may conceal the object of the search.

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

In Phoenix, officers lawfully stop Dana Ortiz's SUV after a reliable informant reports that Dana is transporting methamphetamine somewhere in the vehicle. During the search, officers open a taped shoebox in the cargo area and find drugs.

Were the officers permitted to open the shoebox without first obtaining a warrant?

Explanation. Under the majority rule, if probable cause justifies the search of a lawfully stopped vehicle, officers may search every part of the vehicle and its contents that may conceal the object of the search. The scope turns on the object sought and where it could be hidden, not on whether the item is a closed container.