Stoner v. California Case Brief

Why is the case important?

An individual was convicted of armed robbery after a jury trial. Various items were taken from his hotel room without a search or arrest warrant.

Facts of the case

Question

Whether evidence was admitted during the Petitioner’s trial which had been obtained by an unlawful search and seizure.

Answer

The majority observed our decisions make clear that the rights protected by the Fourth Amendment are not to be eroded by strained applications of the law of agency or by unrealistic doctrines of ‘apparent authority.’
It is important to bear in mind that it was the petitioner’s constitutional right which was at stake here, and not the night clerk’s nor the hotel’s. It was a right, therefore, which only the petitioner could waive by word or deed, either directly or through an agent. It is true that the night clerk clearly and unambiguously consented to the search. But there is nothing in the record to indicate that the police had any basis whatsoever to believe that the night clerk had been authorized by the petitioner to permit the police to search the petitioner’s room.
It is true, as was said in United States v. Jeffers, that when a person engages a hotel room he undoubtedly gives ‘implied or express permission’ to ‘such persons as maids, janitors or repairmen’ to enter his room ‘in the performance of their duties.’ But the conduct of the night clerk and the police in the present case was of an entirely different order. In a closely analogous situation the Court has held that a search by police officers of a house occupied by a tenant invaded the tenant’s constitutional right, even though the search was authorized by the owner of the house, who presumably had not only apparent but actual authority to enter the house for some purposes, such as to ‘view waste.’ The Court pointed out that the officers’ purpose in entering was not to view waste but to search for distilling equipment, and concluded that to uphold such a search without a warrant would leave tenants’ homes secure only in the discretion of their landlords.

Conclusion

The United States Supreme Court reviewed the record, which indicated that defendant’s arrest occurred two days later in another state, and therefore, the arrest could not be the basis for the warrantless search. The Court also held that defendant had a reasonable expectation of privacy in his hotel room and that the hotel clerk did not have authority to give permission to the officers to search defendant’s room. Accordingly, the Court concluded that the evidence that the officers seized was inadmissible in defendant’s trial and reversed his conviction.

  • Case Brief: 1964
  • Petitioner: Stoner
  • Respondent: California
  • Decided by: Warren Court

Citation: 376 US 483 (1964)
Argued: Feb 25, 1964
Decided: Mar 23, 1964