Brief Fact Summary. One and a half hours after arresting the Respondents, Chadwick, Machado, and Leary (Respondents), federal narcotics agents opened a footlocker confiscated during the arrest. The agents had not obtained a warrant to open the footlocker.
Synopsis of Rule of Law. Once property cannot be accessed by an arrestee, it cannot be searched without a warrant.
Facts. The Respondents were arrested by federal narcotics agents as they were lifting a footlocker into the trunk of a car. The agents confiscated the footlocker and moved the Respondents, footlocker, and car to the Federal Building in Boston. An hour and a half after the arrest, the agents unlocked the footlocker without a warrant, consent, or exigent circumstances. Large amounts of marijuana were found in the footlocker.
Issue. Is a search warrant required to open a locked footlocker that was seized during arrest, when there is probable cause to believe that the footlocker contains contraband?