Illinois v. Lafayette

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[?]”

Held.

“The justification for such searches does not rest on probable cause, and hence the absence of a warrant is immaterial to the reasonableness of the search. Indeed, we have previously established that the inventory search constitutes a well-defined exception to the warrant requirement.” Further, “[a]t the station house, it is entirely proper for police to remove and list or inventory property found on the person or in the possession of an arrested person who is to be jailed. A range of governmental interests supports an inventory process. It is not unheard of for persons employed in police activities to steal property taken from arrested persons; similarly, arrested persons have been known to make false claims regarding what was taken from their possession at the station house. A standardized procedure for making a list or inventory as soon as reasonable after reaching the station house not only deters false claims but also inhibits theft or careless handling of articles taken
from the arrested person. Arrested persons have also been known to injure themselves – or others – with belts, knives, drugs, or other items on their person while being detained. Dangerous instrumentalities – such as razor blades, bombs, or weapons – can be concealed in innocent-looking articles taken from the arrestee’s possession. The bare recital of these mundane realities justifies reasonable measures by police to limit these risks – either while the items are in police possession or at the time they are returned to the arrestee upon his release. Examining all the items removed from the arrestee’s person or possession and listing or inventorying them is an entirely reasonable administrative procedure. It is immaterial whether the police actually fear any particular package or container; the need to protect against such risks arises independently of a particular officer’s subjective concerns. Finally, inspection of an arrestee’s personal property may assist the police in ascertain
ing or verifying his identity. In short, every consideration of orderly police administration benefiting both police and the public points toward the appropriateness of the examination of respondent’s shoulder bag prior to his incarceration.”
“Even if less intrusive means existed of protecting some particular types of property, it would be unreasonable to expect police officers in the everyday course of business to make fine and subtle distinctions in deciding which containers or items may be searched and which must be sealed as a unit. Only recently in [New York v. Belton], we stated that “`[a] single familiar standard is essential to guide police officers, who have only limited time and expertise to reflect on and balance the social and individual interests involved in the specific circumstances they confront.’”

Discussion.

This case reiterates that inventory searches are not violative of the constitution.