United States v. Robinson Case Brief

Why is the case important?

The defendant, Robinson (the “defendant”), was pulled over for driving with a revoked license. He was then arrested and the police officer proceeded to do a thorough search of the defendant’s person whereby the officer found a closed cigarette pack which contained heroin.

Facts of the case

A police officer pulled over and arrested Robinson for operating an automobile without a valid permit. The officer then frisked Robinson and discovered a crumpled cigarette package containing fourteen vials of heroin in his pocket.

Question

May a police officer conduct a thorough search of a person beyond frisking for weapons when the arrestee has committed only a traffic offense?

Answer

Yes. A search of an arrestee’s person beyond frisking for weapons is reasonable under the Fourth Amendment of the Constitution, even where there is no reason to believe the arrestee committed any crime other than the traffic violation.

Conclusion

The Supreme Court of the United States reversed the appellate court’s decision. The Court found that the arresting officer clearly was authorized to reach into Robinson’s coat as part of his search because the officer had probable cause to arrest Robinson. Once probable cause to arrest was established, a full search incident to that arrest was authorized in order to protect the officer’s safety and to preserve evidence. A police officer with probable cause to arrest a suspect, even where the arrest was for a traffic violation, was not limited to a protective frisk of the suspect’s clothes for weapons, but rather was authorized to conduct a full search incident to the arrest.

  • Case Brief: 1973
  • Petitioner: United States
  • Respondent: Robinson
  • Decided by: Burger Court

Citation: 414 US 218 (1973)
Argued: Oct 9, 1973
Decided: Dec 11, 1973