United States v. Robinson

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United States v. Robinson
Seal of the United States Supreme Court.svg
Argued October 9, 1973
Decided December 11, 1973
Full case name United States v. Willie Robinson, Jr.
Citations 414 U.S. 218 (more)
94 S.Ct. 467, 38 L.Ed.2d 427
Prior history Certiorari to the United States Court of Appeals for the District of Columbia Circuit
Subsequent history 153 U.S.App.D.C. 114, 471 F.2d 1082, reversed
Holding
In the case of a lawful custodial arrest, a full search of the person is not only an exception to the warrant requirement of the Fourth Amendment, but is also a "reasonable" search under that Amendment.
Court membership
Case opinions
Majority Rehnquist, joined by Burger, Stewart, White, Blackmun, Powell
Concurrence Powell
Dissent Marshall, joined by Douglas, Brennan

United States v. Robinson, 414 U.S. 218 (1973), was a case in which the United States Supreme Court held that "in the case of a lawful custodial arrest a full search of the person is not only an exception to the warrant requirement of the Fourth Amendment, but is also a reasonable search under that Amendment."

Facts[edit]

A D.C. Metro officer stopped a 1965 Cadillac based on reliable information that the driver's operating license had been revoked. All three occupants exited the car, and the officer arrested the driver, Robinson. (For purposes of the Court's opinion, it was assumed that Robinson's full-custody arrest was valid.) The officer proceeded to search Robinson, and felt a package whose contents the officer could not immediately identify. Upon removing the package—a crumpled cigarette packet—and opening it, the officer discovered "14 gelatin capsules of white powder" that turned out to be heroin.

Issue[edit]

Did the officer's search of the defendant violate the Fourth Amendment?

Holding[edit]

According to the Robinson Court "in the case of a lawful custodial arrest a full search of the person is not only an exception to the warrant requirement of the 4th Amendment, but is also a reasonable search under that Amendment."

See also[edit]

Further reading[edit]

  • Aaronson, David E.; Wallace, Rangeley (1976). "A Reconsideration of the Fourth Amendment's Doctrine of Search Incident to Arrest". Georgetown Law Journal 64: 53. 
  • Bradley, Craig M. (1993). "The Court's ‘Two Model’ Approach to the Fourth Amendment: Carpe Diem!". Journal of Criminal Law and Criminology 84 (3): 429–461. JSTOR 1143960. 
  • LaFave, Wayne R. (1974). "‘Case-by-Case Adjudication’ versus ‘Standardized Procedures’: The Robinson Dilemma". The Supreme Court Review 1974: 127–163. JSTOR 3108707. 
  • Nolasco, Claire (2010). "United States v. Robinson". In Del Carmen, Rolando V.; Hemmens, Craig. Criminal Procedure and the Supreme Court. Rowman & Littlefield. pp. 104–116. ISBN 9781442201569.