Florida v. Wells Case Brief

Facts of the Case

Defendant’s car was impounded after he was placed under arrest for driving under the influence, and he gave the state trooper permission to open the car’s trunk. An inventory search of the car turned up a locked suitcase in the trunk. The police forced the suitcase open and found a garbage bag containing a large amount of marijuana inside. Defendant was charged with possession of a controlled substance, and he filed a motion to suppress the marijuana, claiming that the seizure was in violation of the Fourth Amendment. The trial court denied his motion, the state appellate court reversed the trial court’s judgment, and the Supreme Court of Florida affirmed.


Was the Fifth Circuit wrong to reject Banks’ claim relating to Farr’s testimony under Brady v. Maryland on the ground that such a claim must first be made in state court? Was the Fifth Circuit wrong to reject Banks’ claim relating to Cook’s testimony on the grounds that such a claim should have been raised earlier and that Federal Rule of Civil Procedure 15(b) does not apply?


“No. Justice William H. Rehnquist delivered the opinion for five members of the court. The Supreme Court held that there must be a policy in place that determines whether inventory searches include opening closed containers or not. Such a policy allows the situation to be regulated. Absent such a policy, as in this case, the search is not regulated sufficiently to be permissible under the Fourth Amendment. The Fourth Amendment does allow police officers to use discretion in determining whether a container can be opened based on the nature of the search.Justice William J. Brennan, Jr. wrote an opinion concurring in the judgment where he argued that there must be a standard inventory search policy in place that limits police discretion to prevent the abuse of a suspect’s Fourth Amendment rights. Justice Thurgood Marshall joined in the opinion. In his separate opinion concurring in the judgment, Justice Harry A. Blackmun argued that the majority opinion went beyond the bounds of the case by allowing individual police discretion to determine whether to open a sealed container in an inventory search. Justice John Paul Stevens also wrote an opinion concurring in the judgment where he argued that the majority opinion represented blatant judicial activism by granting certiorari to a case that the Florida Supreme Court adequately handled. He also wrote that the majority’s opinion on the issue of police discretion extended beyond the question at hand.””

Case Information

Citation: 495 US 1 (1990)
Argued: Dec 4, 1989
Decided: Apr 18, 1990
Case Brief: 1990