Arkansas v. Sanders

Arkansas v. Sanders, 442 U.S. 753 (1979), was a decision by the United States Supreme Court, which held that absent exigency, the warrantless search of personal luggage merely because it was located in an automobile lawfully stopped by the police, is a violation of the Fourth Amendment and not justified under the automobile exception. Similar to United States v. Chadwick (1977), the luggage was the subject of police suspicion before being placed in the vehicle.

Arkansas v. Sanders
Supreme Court of the United States
Argued February 27, 1979 Decided June 20, 1979
Full case name	Arkansas v. Sanders
Citations	442 U.S. 753 (more) 99 S. Ct. 2586; 61 L. Ed. 2d 235
Case history
Prior	Sanders v. State, 262 Ark. 595, 559 S.W.2d 704 (1977); cert. granted, 439 U.S. 891 (1978).
Holding
Absent exigency, the warrantless search of personal luggage merely because it was located in an automobile lawfully stopped by the police is a violation of the Fourth Amendment and not justified under the automobile exception.
Court membership
Chief Justice Warren E. Burger Associate Justices William J. Brennan Jr. · Potter Stewart Byron White · Thurgood Marshall Harry Blackmun · Lewis F. Powell Jr. William Rehnquist · John P. Stevens
Case opinions
Majority	Powell, joined by Brennan, Stewart, White, Marshall
Concurrence	Burger, joined by Stevens
Dissent	Blackmun, joined by Rehnquist
Laws applied
U.S. Const. amend. IV
Overruled by
California v. Acevedo, 500 U.S. 565 (1991)

Sanders resolved two distinct lines of cases: on the one hand, Carroll v. United States (1925) laid down the automobile exception which allowed for warrantless searches of automobiles; on the other hand, Chadwick did not allow for a warrantless search of luggage. Sanders declined to extend the automobile exception here, again stressing, as in Chadwick, the heightened expectation of privacy in one's luggage.