California v. Acevedo Case Brief

Facts of the case

California police officers saw Charles Acevedo enter an apartment known to contain several packages of marijuana and leave a short time later carrying a paper bag approximately the same size as one of the packages. When Acevedo put the bag in the trunk of his car and began to drive away, the officers stopped the car, searched the bag, and found marijuana. At his trial, Acevedo made a motion to suppress the marijuana as evidence, since the police had not had a search warrant. When the trial court denied his motion, Acevedo pleaded guilty and appealed the denial of the motion. The California Court of Appeal reversed the trial court, ruling that the marijuana should have been suppressed as evidence. The Supreme Court had ruled previously that officers can thoroughly search an automobile if they have probable cause to believe there is evidence somewhere in the vehicle ( U.S. v. Ross ), and also that officers need a warrant to search a closed container ( U.S. v. Chadwick ). The California Court of Appeal decided that the latter case was more relevant. Since the officers only had probable cause to believe the bag contained evidence – not the car generally – they could not open the bag without a search warrant. The California Supreme Court denied review, but the Supreme Court granted the State’s petition.

Why is the case important?

The defendant, Charles Acevedo (“Mr. Acevedo”), put a container in his trunk that the police suspected contained marijuana. The police stopped the defendant and searched the container, leading to the defendant’s arrest.

Question

Whether the police are required to obtain a warrant to search a container in a car – a car that they otherwise lack probable cause to search?

ANSWER

The Fourth Amendment of the Constitution does not require a warrant to search a container in a vehicle if there is probable cause to search the container. This holding applies even if there is no probable cause to search the entire vehicle. This holding clearly negates any former rulings that would give separate treatment to searches specifically for containers in a vehicle.

CONCLUSION

The Court held that the Fourth Amendment did not require the police to obtain a warrant to open the sack in a movable vehicle simply because they lacked probable cause to search the entire car. The same probable cause to believe that a container held drugs allowed the police to arrest the person transporting the container and search it. The police had probable cause to believe that the paper bag in the car’s trunk contained marijuana and probable cause allowed a warrantless search of the paper bag. The Fourth Amendment did not compel separate treatment for an automobile search that extended only to a container within the vehicle. The police could search containers found in an automobile without a warrant if their search was supported by probable cause. The judgment concluding that marijuana found in a paper bag in the trunk of a car should have been suppressed was reversed, and the case was remanded for further proceedings consistent with the Court’s opinion.

  • Advocates: Robert Foster on behalf of the Petitioner Fred W. Anderson on behalf of the Respondent
  • Petitioner: California
  • Respondent: Acevedo
  • DECIDED BY:Rehnquist Court
  • Location: Acevedo’s Car
Citation: 500 US 565 (1991)
Argued: Jan 8, 1991
Decided: May 30, 1991
California v. Acevedo Case Brief