US v CHADWICK Essay Example
The case of US v Chadwick reinforces the protection of privacy interests under the Warrant Clause of the Fourth Amendment. The Clause protects individuals from unreasonable searches and seizures by the government or its agents. As a result, the invasion of privacy interests by the government must be justified through a warrant issued by a neutral magistrate. This position was reinforced in the US v Chadwick case where the court held that the action of Federal Agents to open and search a locked footlocker belonging to the respondents without a warrant or their consent was a violation of the Fourth Amendment. The Court of Appeals affirmed the suppression of the evidence seized and held that probable cause was not enough to sustain a warrantless search.
US v Chadwick, 433 US 1 (1977)
Facts of the Case
The case is an appeal by the United States (US) government against a suppression of evidence in a narcotics case involving the distribution of marijuana. The respondents had been arrested after they arrived in Boston by train while carrying a double-locked footlocker which they were loading in the trunk of the vehicle. The federal narcotics agents had been alerted that the respondents were possible drug traffickers hence the agents had reason to believe that the footlocker contained narcotics. The agents in Boston had bought a dog which signaled that the footlocker contained narcotics (United States Government Publishing Office, 2016).
Once arrested, the respondents, their automobile, and the footlocker were taken to the Federal Building in Boston. One and a half hours after the respondents were arrested, the agents opened the respondent’s footlocker without either the respondents’ consent or a warrant where they found marijuana. The respondents were later charged with possession of marijuana with intent to distribute it. During the pretrial process, the respondents raised a motion to suppress the evidence of marijuana obtained from the footlocker on the ground that the evidence had been obtained based on a warrantless search (United States Government Publishing Office, 2016). The Court granted the motion by the respondents. The government sought to have the Court of Appeals review the order of the District Court on the suppression of marijuana.
The issue to be decided by the Court was whether the agents in Boston had violated the Fourth Amendment by opening a locked footlocker without a warrant or consent from the respondents.
The Court upheld the decision of the District Court and held that the action of the agents involving the opening of the footlocker without a warrant or consent violated the Fourth Amendment. The Court stated that the respondents were protected by the Warrant Clause hence before their right to privacy was invaded, the evaluation of a magistrate was needed through the issuing of a warrant.
Reasoning of the Court
The decision of the court was based on the fact that the purpose of the Fourth Amendment was to protect individuals from unreasonable invasions of their privacy interests by the government. Such protection on privacy interests was not only applied to a person’s home. The court stated that the fact that the respondents had placed their personal effects in a double-locked footlocker showed that they expected that it would remain fee from any public examination (United States Government Publishing Office, 2016). Just like a person who locks his home against intruders, such a person is also entitled to the protection of the Warrant Clause. Further, the court stated that since there was no urgency that would call for an immediate search, the government agents ought to have waited until they acquired a warrant. The fact that the search was conducted one and a half hours after the arrest meant that the search was unjustifiable as one that was incident to a lawful arrest. The court also found that the automobile exception could not justify the government’s actions since an individual’s privacy expectations are greater in footlocker than a vehicle.
Justices Blackmun and Rehnquist dissented from the judgment of the court stating that once an officer has arrested a suspect, no warrant is required for such an officer to search the effects of such suspect held in custodial arrest. A custodial arrest of a suspect which is based on probable cause is a lawful intrusion. This means that a search incident to such arrest does not require any further justification.
Opinion and Conclusion
I agree with the decision by the majority of the court that the Federal Agents invaded the privacy interests of the respondents by searching the double-locked footlocker without a warrant or the permission of the respondents. Due to such invasion, the court was justified in affirming the suppression of the marijuana recovered as evidence from the search. The Warrant Clause of the Fourth Amendment safeguards the right of every individual to be protected against unreasonable searches. It acknowledges that the right of every person to be secure in their houses, persons and effects should not be violated unless a warrant is issued. According to Stelzner (2010), a search is considered unreasonable unless it is authorized by a warrant or it is one of the exceptions that are justified by absolute necessity. The court upheld this position in Katz v United States where the Court stated that searches without warrants are per se unreasonable (Bar-Gill & Friedman, 2012). Searches without warrants are, therefore, prohibited by the Fourth Amendment unless a search without a warrant falls under a defined exception (Stelzner, 2010). The search conducted by the agents who arrested the respondents in the case of US v Chadwick was done without a warrant. As a result, the search is unreasonable unless the government could show that the search was justified under one of the defined exceptions.
The exceptions to the Warrant Clause include plain view exception, consent, search incident to lawful arrest, stop and frisk and automobile exception among others. In the US v Chadwick case, the government relied on the search incident to lawful arrest and the automobile exceptions. The court established the automobile exception in Carroll v United States 267 US 132 where the court held that vehicles may be searched without a warrant where an officer undertaking the search has probable cause to believe that such vehicle contains contraband (United States Government Publishing Office, 2016). In the US v Chadwick case, the court rightly stated that the automobile exception did not apply since there was a difference between the footlocker and the vehicle. Further, due to the time that had passed after the arrest, the search incident to lawful arrest exception could also not apply. As a result, nothing could justify the search by the agents hence it was unreasonable.
The principal objective of the Fourth Amendment is to protect the privacy of individuals. To allow the government or its agents to invade a person’s privacy without lawful justification would be tantamount to violating a person’s right. A debate has emerged on whether the exclusionary rule should continue to apply given that it may lead to criminals being set free even where there is enough evidence to convict them (Bar-Grill & Friedman, 2012). However, the provisions of the Fourth Amendment must be adhered to ensure that individual rights guaranteed by the law are safeguarded.
Bar-Grill, O. & Friedman, B. (2012). Taking warrants seriously. Northwestern University Law Review, 106(4), 1609-1674.
Stelzner, L. (2010). The Fourth Amendment: The reasonableness and warrant clauses. New Mexico Law Review, 10(4), 33-49.
United States Government Publishing Office (2016). Fourth Amendment: Search and seizure. Retrieved September 16, 2016, from: www.gpo.gov
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