United States v. Matlock Case Brief

Why is the case important?

The home that a robbery suspect was leasing was searched by the police after obtaining the consent to enter the home from somebody who lived with the suspect.

Facts of the case

“Police arrested William Earl Matlock, a bank robbery suspect, in the front yard of the house where he lived. Police did not ask Matlock which room he occupied in the house or whether they could conduct a search. A woman, who gave them permission to search the house, including the bedroom where Matlock lived, let the officers inside. The woman’s parents leased the house and Matlock paid them rent for his room. In that room, police found $4,995 in cash.At trial, Matlock moved to suppress evidence obtained during the search. He argued that the unwarranted search of his room was illegal. At the suppression hearing, the woman who agreed to the search testified that she lived with Matlock in his room. This gave her sufficient authority to lawfully consent to the search. The district court held that those statements were inadmissible hearsay and granted the motion to suppress. The U.S. Court of Appeals for the Seventh Circuit Affirmed.”

Question

Whether the evidence presented by the United States with respect to the voluntary consent of a third party to search the living quarters of the respondent was legally sufficient to render the seized materials admissible in evidence at the respondent’s criminal trial?

Answer

The court first observed that recent decisions clearly indicate that the consent of one who possesses common authority over premises or effects is valid as against the absent, nonconsenting person with whom that authority is shared.
It appears to us, given the admissibility of Mrs. Graff’s and respondent’s out-of-court statements, that the Government sustained its burden of proving by the preponderance of the evidence that Mrs. Graff’s voluntary consent to search the east bedroom was legally sufficient to warrant admitting into evidence the $4,995 found in the diaper bag.

Conclusion

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  • Case Brief: 1974
  • Petitioner: United States
  • Respondent: William Earl Matlock
  • Decided by: Burger Court

Citation: 415 US 164 (1974)
Argued: Dec 10 – 11, 1973
Decided: Feb 20, 1974
Granted May 29, 1973