California v. Acevedo Case Brief

Search and Seizure Case Briefs

California v. Acevedo, 500 U.S. 565, 111 S. Ct. 1982 (1991)

FACTS: On October 28, 1987, Officer Coleman of the Santa Ana Police Department received a call from a DEA agent in Hawaii. The agent told Coleman that he had seized a package of marijuana from Federal Express, which was to have been delivered to Daza, in Santa Ana. The agent then sent to package to Coleman, who was to allow Daza to claim the package at the Federal Express office.

Daza claimed the package, and returned to his apartment. Shortly afterward, he left, and was observed disposing of a box and paper in an outside trash container. Coleman went to get a search warrant. A few minutes later, St. George left the apartment, carrying a knapsack. He was stopped, and the knapsack was found to contain over a pound of marijuana.

A little later, Acevedo arrived at the apartment. He stayed a few moments, then left with a full paper bag. The bag was approximately the size of one of the wrapped marijuana packages. He placed the bag in the trunk of his car. At that moment, the officers stopped him and searched the package, finding marijuana.

Acevedo was convicted, but appealed. The lower court, facing confusing rulings in earlier Supreme Court cases, found for Acevedo.

ISSUE: Is a package in the trunk of a car, for which probable cause exists to believe contains contraband, subject to search without a warrant?

HOLDING: Yes

DISCUSSION: The Court outlined the history of search as it relates to automobiles, from Carroll forward. The Court concluded “[I]f destroying the interior of an automobile is not unreasonable, we cannot conclude that looking inside a closed container is.” The Court extended the interpretation of the Carroll doctrine in Ross to apply to all searches of containers found in an automobile, stating that “the police may search without a warrant if their search is supported by probable cause.” The Court however, limited the decision by stating that probable cause to search a particular package for contraband does not necessarily extend to probable cause to search the entire vehicle.