United States v. Chadwick, 433 U.S.

1 (1977)

Doctrine: A fundamental purpose of the Fourth Amendment is to safeguard individuals from

unreasonable government invasions of legitimate privacy interests, and not simply those interests
inside the four walls of the home.

By placing personal effects inside a double-locked footlocker, respondents manifested an expectation

that the contents would remain free from public examination, and, no less than one who locks the
doors of his home against intruders, one who safeguards his personal possessions in this manner is
due the protection of the Fourth Amendment's Warrant Clause; since there was no exigency calling
for an immediate search, it was unreasonable for the Government to conduct the search without the
safeguards a judicial warrant provides.

SUMMARY/FACTS: When respondents arrived by train in Boston from San Diego, they were
arrested at their waiting automobile by federal narcotics agents, who had been alerted that
respondents were possible drug traffickers. A double-locked footlocker, which respondents had
transported on the train and which the agents had probable cause to believe contained
narcotics, had been loaded in the trunk of the automobile. Respondents, together with the
automobile and footlocker, which was admittedly under the agents' exclusive control, were
then taken to the Federal Building in Boston. An hour and a half after the arrests, the agents
opened the footlocker without respondents' consent or a search warrant, and found large
amounts of marihuana in it. Respondents were subsequently indicted for possession of
marihuana with intent to distribute it.

District Court: granted their pretrial motion to suppress the marihuana obtained from the
footlocker, holding that warrantless searches are per se unreasonable under the Fourth
Amendment unless they fall within some established exception to the warrant requirement,
and that the footlocker search was not justified under either the "automobile exception" or as a
search incident to a lawful arrest;

Court of Appeals affirmed.

Issue: WON the warrantless search was invalid (YES)

RULING:

Respondents were entitled to the protection of the Warrant Clause of the Fourth Amendment,
with the evaluation of a neutral magistrate, before their privacy interests in the contents of the
footlocker were invaded.

(a) A fundamental purpose of the Fourth Amendment is to safeguard individuals from

unreasonable government invasions of legitimate privacy interests, and not simply those
interests inside the four walls of the home.

(b) By placing personal effects inside a double-locked footlocker, respondents manifested an

expectation that the contents would remain free from public examination, and, no less than
one who locks the doors of his home against intruders, one who safeguards his personal
possessions in this manner is due the protection of the Fourth Amendment's Warrant Clause;
since there was no exigency calling for an immediate search, it was unreasonable for the
Government to conduct the search without the safeguards a judicial warrant provides.

 WON Diminished expectation of privacy applies to luggage or footlocker. (NO)

Luggage contents are not open to public view, except as a condition to a border
entry or common carrier travel; nor is luggage subject to regular inspections and
official scrutiny on a continuing basis. Unlike an automobile, whose primary function
is transportation, luggage is intended as a repository of personal effects. In sum, a
person's expectations of privacy in personal luggage are substantially greater than in
an automobile. The warrantless search is invalid
 The footlocker search was not justified under the "automobile exception," since a
person's expectations of privacy in personal luggage are substantially greater than in
an automobile. In this connection, the footlocker's mobility did not justify dispensing
with a search warrant, because, once the federal agents had seized the footlocker at
the railroad station and safely transferred it to the Federal Building under their
exclusive control, there was not the slightest danger that it or its contents could
have been removed before a valid search warrant could be obtained

 WON the footlocker search was justified as a search incident to a lawful arrest (NO)

Here, the search was conducted more than an hour after federal agents had gained
exclusive control of the footlocker and long after respondents were securely in
custody; the search therefore cannot be viewed as incidental to the arrest or as
justified by any other exigency. Even though on this record the issuance of a warrant
by a judicial officer was reasonably predictable, a line must be drawn. In our view,
when no exigency is shown to support the need for an immediate search, the
Warrant Clause places the line at the point where the property to be searched comes
under the exclusive dominion of police authority. Respondents were therefore
entitled to the protection of the Warrant Clause before their privacy interests in the
contents of the footlocker were invaded.