Arkansas v. Sanders Case Brief

Search and Seizure Case Briefs
By Kentucky Justice & Public Safety Cabinet
Jul 19, 2001

Arkansas v. Sanders, 442 U.S. 753, 99 S.Ct. 2586 (1979)

FACTS: An officer of the Little Rock P.D. received word from an informant that Sanders would arrive at a particular gate, at a particular time, carrying a green suitcase with marijuana. Both the officer and the informant knew Sanders well, having worked on a case involving Sanders before, a case that resulted in Sanders conviction.

Sanders arrived as expected, and met with a man later identified as Rambo. While Rambo stood by, Sanders retrieved a suitcase from baggage claim; he then handed the case to Rambo. Sanders went outside and entered a taxi, where he had earlier placed his carry-on luggage. In a few minutes Rambo joined him, placing the suitcase in the trunk. The taxi drove away.

Officers pursued and stopped the taxi, and the taxi driver opened the trunk at their request. Without asking permission, officers opened the case and found almost ten pounds of marijuana, packaged in separate bags.

ISSUE: Can officers lawfully open a suitcase in the trunk of a vehicle under these circumstances?


DISCUSSION: The Court held that an anonymous tip that is unsupported by specific information is not sufficient to satisfy the requirement of Terry that an officer have reasonable suspicion before initiating a search. In this case, the officers had nothing but an anonymous tip about an individual carrying a firearm. An exception strictly because a firearm is alleged would subject individuals to the potential for harassment by officers acting solely on anonymous tips that may, or may not, be credible. The Court insists on at least an indicia of reliability and credibility in anonymous tips.

The Court specifically stated that this case does not reach to areas where an individual has a diminished expectation of privacy, such as airports and schools.