U. S. v. Chadwick Case Brief

U. S. v. Chadwick, 433 U.S. 1, 97 S.Ct. 2476 (1977)

FACTS: On May 8, 1973 Amtrak officials in San Diego observed Machado and Leary load a footlocker onto a train bound for Boston. Their suspicions were aroused when they noticed that the trunk seemed unusually heavy for its size, and that it was leaking talcum powder, a substance often used to mask the odor of drugs. Machado also fit a drug-courier profile used by the railroad. The railroad officials notified DEA in San Diego who in turn notified DEA in Boston.

In Boston, DEA agents did not have a search or arrest warrant, but they did have a drug dog. The agents observed Machado and Leary as they claimed their baggage and the footlocker. The agents released the drug dog near the footlocker and he alerted on the locker. Chadwick met Machado and Leary at the station, and together they lifted the 200- pound footlocker into the trunk of Chadwick’s car. At that point (app. 9:00 p.m.), while the trunk of the car was open and before the car engine had been started, the officers arrested all three. A search incident to arrest produced the keys to the footlocker from Machado. All three were taken to the Federal Building in Boston. The agents followed with Chadwick's car and the footlocker. At all times, the footlocker remained in the possession and control of the agents. At app. 10:30 p.m., the agents opened the footlocker. It contained large amounts of marijuana. The agents did not have consent of respondents to search, nor did they have a warrant.

ISSUE: Was the search lawful?

HOLDING: No

DISCUSSION: The Fourth Amendment protects people, not places. By placing personal effects inside a locked footlocker, defendants showed that they expected privacy. There being no exigency, it was unreasonable for the Government to conduct a search of the footlocker without a warrant, even where the agents lawfully seized the footlocker at the time of the arrest of its owners and there was probable cause to believe that it contained contraband. A footlocker's mobility did not justify dispensing with warrant by analogy to the "automobile exception" once agents had seized it and had it under their exclusive control. Since defendant’s principal privacy interest was not in the container itself, but in its contents, seizure of the locker did not diminish their legitimate expectation that its contents would remain private. Search incident of arrest of luggage after the arrest cannot be justified as incident to arrest if search is remote in time or place from the arrest.