Robbins v. California

Facts of the Case

California Highway Patrol officers stopped a 1966 station wagon because they observed the vehicle being driven erratically. Upon smelling marihuana smoke, one of the officers patted the driver, defendant Jeffrey Richard Robbins, down, discovering a vial of liquid, and then searched the passenger compartment of the car, finding marihuana as well as equipment for using it. After placing Robbins in the patrol car, the officers opened the tailgate of the station wagon, located a handle set flush in the deck, and lifted it up to uncover a recessed luggage compartment. In the compartment were two packages wrapped in green opaque plastic which the officers then unwrapped and found to contain bricks of marihuana. Robbins was subsequently charged with various drug offenses, his pretrial motion to suppress the evidence found when the packages were unwrapped was denied, and he was convicted. The Court of Appeal of California affirmed the conviction, ruling that the warrantless opening of the packages was constitutionally permissible since the trial court could reasonably have concluded that the contents of the packages could have been inferred from their outward appearance, such that Robbins could not have held a reasonable expectation of privacy with respect to the contents. The United States Supreme Court granted defendant’s petition for certiorari.

Question

May police officers search closed containers found during a lawful, warrantless search of an automobile?

CONCLUSION

No. Justice Potter Stewart delivered the opinion of the 6-3 plurality. The plurality opinion held that the automobile exception to the warrant requirement under the Fourth Amendment did not extend to closed and opaque containers found during the search. According to the plurality of the Court, the record in the case did not support the appellate court’s finding that Robbins did not have a reasonable expectation of privacy.Chief Justice Warren E. Burger concurred in the judgment of the Court. In an opinion concurring in the judgment, Justice Lewis F. Powell wrote that the careful manner in which the packages containing the marijuana were wrapped and sealed demonstrated Robbins’s intention to keep their contents private. However, he argued that the plurality opinion imposed too heavy a burden on police officers by requiring them to obtain a warrant to search every closed container found during a lawful, warrantless search of an automobile.Justice Harry A. Blackmun wrote a dissent in which he argued that the automobile exception to the warrant requirement should authorize police officers to seize and search any personal containers found within the vehicle. Justice William H. Rehnquist wrote a separate dissent in which he agreed with Justice Blackmun’s proposed rule. He also expressed opposition to the practice of excluding evidence obtained through impermissible means, especially with the Court’s extension of exclusionary rule to state law enforcement agencies in Mapp v. Ohio.He argued that the harshness of the rule created an unfair advantage for the suspects because it required police officers to not only understand the nuanced case law surrounding the Fourth Amendment, but also to make the correct decision instantly. Justice John Paul Stevens wrote a separate dissent in which he argued that the scope a lawful, warrantless search should include any container that a magistrate could authorize by warrant. As the police officers searched the car for evidence of contraband, the fact that the packages were tightly wrapped and sealed was of little consequence.

Case Information

  • Citation: 453 US 420 (1981)
  • Argued: Apr 27, 1981
  • Decided Jul 1, 1981