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Illinois v. Lafayette

Law Dictionary

Law Dictionary

Featuring Black's Law Dictionary 2nd Ed.
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Criminal Procedure keyed to Weinreb

Citation. Illinois v. Lafayette, 462 U.S. 640, 103 S. Ct. 2605, 77 L. Ed. 2d 65, 1983 U.S. LEXIS 71 (U.S. June 20, 1983)

Brief Fact Summary. After an individual was arrested, his bag was searched as part of an inventory of his belongings and drugs were found in a cigarette package.

Synopsis of Rule of Law. “[I]t is not ”unreasonable’ for police, as part of the routine procedure incident to incarcerating an arrested person, to search any container or article in his possession, in accordance with established inventory procedures.”

Facts. The Respondent, Lafayette (the “Respondent”) was arrested for partaking in an altercation with a movie theater manager. The Respondent was arrested and he had a purse-type shoulder bag with him on the trip to the police station. While at the station, the Respondent took a pack of cigarettes out of the bag and the officer found drugs in the cigarette package. The Respondent was charged with violating Illinois’ state drug laws.
At a pre-trial suppression hearing, the trial court ordered suppression of the drugs. The Appellate Court affirmed and found that the state waived its argument that the search was incident to a valid arrest. Further, that the search was not a valid inventory of respondent’s belongings.

Issue. “[W]hether, consistent with the Fourth Amendment, it is reasonable for police to search the personal effects of a person under lawful arrest as part of the routine administrative procedure at a police station house incident to booking and jailing the suspect[?]”

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