Rakas v. Illinois Case Brief

Why is the case important?

Passengers in a car attempted to suppress shotgun shells found in the car.

Facts of the case

Question

Whether standing can be established in the absence of ownership of the property seized.

Answer

No. Despite the petitioners’ arguments, the Court did not accept the target theory, and reaffirmed Jones v. United States. The petitioners had no standing. The Court further distinguished from Jones in that the petitioners did no have a legally sufficient interest in a place other than his own home. The petitioners could not legitimately expect privacy in the areas which were the subject of the search and seizure each sought to contest.

Conclusion

The Supreme Court of the United States held that petitioners were not entitled to challenge the search as violative of the Fourth Amendment, since the search did not violate any of their rights. The Court averred that the appropriate measure of rights was no longer guided solely by whether petitioners were legitimately on the premises that the police searched. Without holding that a property interest was required, the Court decided that U.S. Const. amend. IV protected only those places in which petitioners themselves had a reasonable expectation of privacy. Using this analysis, the Court found that petitioners’ rights were not violated where they had no legitimate expectation of privacy in areas of a car in which they claimed no property or possessory interest.

  • Case Brief: 1978
  • Petitioner: Rakas
  • Respondent: Illinois
  • Decided by: Burger Court

Citation: 439 US 128 (1978)
Argued: Oct 3, 1978
Decided: Dec 5, 1978