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.
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?
Held. Yes. Personal effects that have been confiscated by the police incident to an arrest cannot be searched without a warrant, unless exigent circumstances exist.
With the footlocker safely immobilized, it was unreasonable to undertake the additional and greater intrusion of a search without a warrant.View Full Point of Law