California v. Acevedo
Significance: The Supreme Court held that the police may search either an automobile or a closed container in an automobile without a search warrant provided that the search is supported by probable cause.
The Acevedo decision established “one clear-cut rule” for searches of both automobiles and containers within automobiles. After 1925 the Supreme Court had allowed the police to stop and search moving vehicles on probable cause without a search warrant. In United States v. Chadwick (1977), however, the Court held that the police needed a warrant to search a sealed container, even when the container was located in an automobile. Then in United States v. Ross (1982), the Court allowed the police to search any containers that happened to be located in an automobile that was being searched on the basis of probable cause. The combination of Chadwick and Ross often confused judges and the police. When the police observed Charles Acevedo put a brown bag into the trunk of his car, they had probable cause to think that the bag contained marijuana. Although the police had no other justification to search the car, they nevertheless took the bag from the trunk and opened the bag without getting a warrant. California courts, in conformity with Chadwick, ruled that the marijuana in the bag could not be used as evidence in a criminal trial. By a 6-3 vote, however, the Supreme Court reversed the Chadwick ruling. Justice Harry A. Blackmun's majority opinion argued that the Fourth Amendment's protection of privacy should not depend on “coincidences” such as whether the probable cause referred to the automobile or to the container.