United States v. Edwards Case Brief

Why is the case important?

After spending the night in jail, the Respondent’s, Edwards (Respondent), clothes were exchanged for fresh clothing. The clothing that the Respondent had worn was kept by the police to be used as evidence against the Respondent.

Facts of the case


Is clothing taken 10 hours after arrest excluded from evidence as the fruits of an unlawful search?


No. Searches and seizures that may occur during arrest may also be conducted when the accused arrives at the place of detention. Anything found by the police during the course of a warrantless search incident to arrest or incarceration is admissible. Additionally, anything found by the police while holding an arrestee’s property is admissible.


The Court held that the search and seizure of Edwards’ clothing did not violate the Fourth Amendment . The Court ruled that the search and seizure of the defendant’s clothing was a normal incident of custodial arrest and that it was reasonable because of the existence of probable cause linking the clothes to the crime. Furthermore, it was held that once an accused has been lawfully arrested and is in custody, the effects in his possession at the place of detention that were subject to search at the time and place of arrest may lawfully be searched and seized without a warrant even after a substantial time lapse between the arrest and later administrative processing, on the one hand, and the taking of the property for use as evidence, on the other.

  • Case Brief: 1974
  • Petitioner: United States
  • Respondent: Edwards
  • Decided by: Burger Court

Citation: 415 US 800 (1974)
Argued: Jan 15, 1974
Decided: Mar 26, 1974