U.S. v. Robinson Case Brief

U.S. v. Robinson, 414 U.S. 218, 94 S. Ct. 467 (1973)

FACTS: On April 23, 1968, Officer Jenks of the District of Columbia Metropolitan Police Department, observed Robinson driving. Jenks knew that he had just checked on the status of Robinson’s operator’s permit four days before and found it revoked. He made a traffic stop of the vehicle. All three of the occupants got out of the vehicle. Jenks arrested Robinson for the offense.

In accordance with policy, Jenks searched Robinson. He found a cigarette package containing 14 capsules of heroin, and he was eventually convicted for that offense. Robinson argued that Jenks exceeded the scope of permissible search by going beyond a “frisk.”

ISSUE: Does a full search of a person exceed the scope of “search incident to arrest?”

HOLDING: No

DISCUSSION: The Court held that it was “well settled that a search incident to a lawful arrest is a traditional exception to the warrant requirement of the Fourth Amendment.” The Court explored the history of the concept, and found very little had been written in case law and legal treatise on the subject. The Court was unwilling to limit the scope of such searches based upon the offense committed, as the rationale for the search However, the Court concluded that a full search following a lawful arrest was not only an exception to the warrant requirement, but a reasonable search under the Fourth Amendment as well.