United States v. Robinson

United States v. Robinson, 414 U.S. 218 (1973), was a case in which the United States Supreme Court held that "in the case of a lawful custodial arrest a full search of the person is not only an exception to the warrant requirement of the Fourth Amendment, but is also a reasonable search under that Amendment."

United States v. Robinson
Supreme Court of the United States
Argued October 9, 1973
Decided December 11, 1973
Full case nameUnited States v. Willie Robinson, Jr.
Citations414 U.S. 218 (more)
94 S. Ct. 467; 38 L. Ed. 2d 427
Case history
Prior471 F.2d 1082 (D.C. Cir. 1973)
Holding
In the case of a lawful custodial arrest, a full search of the person is not only an exception to the warrant requirement of the Fourth Amendment, but is also a "reasonable" search under that Amendment.
Court membership
Chief Justice
Warren E. Burger
Associate Justices
William O. Douglas · William J. Brennan Jr.
Potter Stewart · Byron White
Thurgood Marshall · Harry Blackmun
Lewis F. Powell Jr. · William Rehnquist
Case opinions
MajorityRehnquist, joined by Burger, Stewart, White, Blackmun, Powell
ConcurrencePowell
DissentMarshall, joined by Douglas, Brennan

Facts

A Washington D.C. Metropolitan police officer stopped a 1965 Cadillac based on reliable information that the driver's operating license had been revoked. All three occupants exited the car, and the officer arrested the driver, Robinson. (For purposes of the Court's opinion, it was assumed that Robinson's full-custody arrest was valid.) The officer proceeded to search Robinson, and felt a package whose contents the officer could not immediately identify. Upon removing the package—a crumpled cigarette packet—and opening it, the officer discovered "14 gelatin capsules of white powder" that turned out to be heroin.

Issue

Did the officer's search of the defendant violate the Fourth Amendment?

Holding

According to the Court "in the case of a lawful custodial arrest a full search of the person is not only an exception to the warrant requirement of the 4th Amendment, but is also a reasonable search under that Amendment."

See also

Further reading
  • Aaronson, David E.; Wallace, Rangeley (1976). "A Reconsideration of the Fourth Amendment's Doctrine of Search Incident to Arrest". Georgetown Law Journal. 64: 53.
  • Bradley, Craig M. (1993). "The Court's 'Two Model' Approach to the Fourth Amendment: Carpe Diem!". Journal of Criminal Law and Criminology. 84 (3): 429–461. doi:10.2307/1143960. JSTOR 1143960.
  • LaFave, Wayne R. (1974). "'Case-by-Case Adjudication' versus 'Standardized Procedures': The Robinson Dilemma". The Supreme Court Review. 1974: 127–163. doi:10.1086/scr.1974.3108707. JSTOR 3108707.
  • Nolasco, Claire (2010). "United States v. Robinson". In Del Carmen, Rolando V.; Hemmens, Craig (eds.). Criminal Procedure and the Supreme Court. Rowman & Littlefield. pp. 104–116. ISBN 9781442201569.
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