United States v. Chadwick

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?

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.

Discussion. The Fourth Amendment protects people, not places. Because people have a legitimate expectation of privacy in their personal effects, a warrant is required to search confiscated luggage.