United States v. Place Case Brief

Why is the case important?

DEA agents met the respondent, Raymond Place, on Friday at his destination after questionable behavior at his departing airport. They then proceeded to hold his bags over the weekend and get a search warrant for them Monday morning.

Facts of the case

“(Tom Feledy prepared this summary.)A traveler at an airport alerted the suspicions of drug agents, who, based upon his behavior and discrepancies in his luggage tags, believed he was carrying narcotics. They relayed this information to fellow agents at his destination airport. There, the agents met him and seized his bags without his consent. Ninety minutes after the seizure, his bags were subjected to a “”sniff”” test by a drug-detection dog. The dog signaled the presence of a controlled substance in one of the bags. The agents then obtained a warrant for that suitcase, which turned out to contain cocaine, and the man was convicted of the drug offense. The Court of Appeals reversed his conviction on the ground that the ninety minutes exceeded the investigative stop permitted by _Terry v. Ohio, and thus violated the Fourth Amendment’s search and seizure privilege.”

Question

Does the seizure of a person’s luggage for an entire weekend until a warrant may be procured violate the Fourth Amendment as exceeding the limits of a Terry stop?
Is the canine sniff of a narcotics dog a search for Fourth Amendment purposes?

Answer

Affirm the decision of the Second Circuit.
When there is reasonable suspicion that a traveler is carrying narcotics in their luggage, the concepts of Terry allow the officer to detain the luggage temporarily to investigate the circumstances, as long as the investigative detention is appropriately limited in scope. However, the actions here went beyond the scope allowable under Terry since the luggage was held for three days, thus it is in violation of the Fourth Amendment.

Conclusion

The Court affirmed the reversal of defendant’s conviction on the basis that the evidence obtained from the search was inadmissible. The 90-minute detention of defendant’s luggage went beyond the narrow authority possessed by police to detain briefly luggage reasonably suspected to contain narcotics. The violation was exacerbated by the agents’ failure to accurately inform the defendant where they were transporting his bags, how long he might be dispossessed, and what arrangements would be made for return of the bags if the investigation dispelled the suspicion. Under the circumstances, the seizure of defendant’s luggage violated the Fourth Amendment . Accordingly, the evidence obtained from the subsequent search of the luggage was inadmissible, and defendant’s conviction must be reversed.

  • Case Brief: 1983
  • Petitioner: United States
  • Respondent: Raymond J. Place
  • Decided by: Burger Court

Citation: 462 US 696 (1983)
Argued: Mar 2, 1983
Decided: Jun 20, 1983