Ohio v. Robinette

Facts of the Case

After an Ohio deputy sheriff stopped respondent Robinette for speeding, gave him a verbal warning, and returned his driver’s license, the deputy asked whether he was carrying illegal contraband, weapons, or drugs in his car. Robinette answered no and consented to a search of the car, which revealed a small amount of marijuana and a pill. He was arrested and later charged with knowing possession of a controlled substance when the pill turned out to be methylenedioxy-methamphetamine. Following denial of his pretrial suppression motion, he was found guilty, but the Ohio Court of Appeals reversed on the ground that the search resulted from an unlawful detention. The State Supreme Court affirmed, establishing as a bright-line prerequisite for consensual interrogation under these circumstances the requirement that an officer clearly state when a citizen validly detained for a traffic offense is legally free to go. The Supreme Court of the United States granted certiorari to review this per se rule.

Question

Does the Fourth Amendment’s protection against illegal search and seizures require that a lawfully detained defendant be told that he is free to go before he can be said to have voluntarily agreed to any subsequent search?

CONCLUSION

No. After establishing its federal jurisdiction, despite a claim that the matter involved aspects of Ohio’s Constitution, the Court held that when looking at the totality of the circumstances it may be reasonably concluded that if a defendant consents to be searched, even if not first advised that he is free to go, the ensuing search will be recognized as voluntary. The Court also added that Robinette’s arrest on drug possession charges was lawful, even though the arresting officer did not stop him on an initial suspicion of drug possession nor intend to even issue him a speeding ticket.

Case Information

  • Citation: 519 US 33 (1996)
  • Argued: Oct 8, 1996
  • Decided Nov 18, 1996