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United States v. Ross – Case Brief

Justice STEVENS delivered the opinion of the Court.

Relevant Facts:
In the evening of November 27, 1978, an informant who had previously proved to be reliable telephoned Detective Marcum of Colombia police Department and told him that an individual known as "Bandit" was selling narcotics kept in the trunk of a car parked at 439 Ridge Street. The informant stated that he had just observed "Bandit" complete a sale and that "Bandit" had told him that additional narcotics were in the trunk. The informant gave Marcum a detailed description of "Bandit" and stated that the car was a "purplish maroon" Chevrolet Malibu with DC license plates. Accompanied by Detective Cassidy and Sergeant Gonzales, Marcum immediately drove to the area and found a maroon Malibu parked in front of 439 Ridge Street. The car was registered to Albert Ross; a computer check on Ross revealed that he fit the informant's description and used the alias "Bandit." In two passes through the neighborhood the officers did not observe anyone matching the informant's description. To avoid alerting persons on the street, they left the area. The officers returned five minutes later and observed the maroon Malibu turning off Ridge Street onto Fourth Street. They pulled alongside the Malibu, noticed that the driver matched the informant's description, and stopped the car. Marcum and Cassidy told the driver -- later identified as Albert Ross, the respondent in this action -- to get out of the vehicle. While they searched Ross, Sergeant Gonzales discovered a bullet on the car's front seat. He searched the interior of the car and found a pistol in the glove compartment. Ross then was arrested and handcuffed. Detective Cassidy took Ross' keys and opened the trunk, where he found a closed brown paper bag. He opened the bag and discovered a number of glassine bags containing a white powder. Cassidy replaced the bag, closed the trunk, and drove the car to headquarters. At the police station Cassidy thoroughly searched the car. In addition to the "lunch-type" brown paper bag, Cassidy found in the trunk a zippered red leather pouch. He unzipped the pouch and discovered $3,200 in cash. The police laboratory later determined that the powder in the paper bag was heroin. No warrant was obtained.

Prior History:
Ross was charged with possession of heroin with intent to distribute. Prior to trial, he moved to suppress the heroin found in the paper bag and the currency found in the leather pouch. After an evidentiary hearing, the District Court denied the motion to suppress. The heroin and currency were introduced in evidence at trial and Ross was convicted. A three-judge panel of the Court of Appeals reversed the conviction. It held that the police had probable cause to stop and search Ross' car and that, under Carroll v. United States, supra, and Chambers v. Maroney, 399 U.S. 42, the officers lawfully could search the automobile -- including its trunk -- without a warrant. The court considered separately, however, the warrantless search of the two containers found in the trunk. On the basis of Arkansas v. Sanders, 442 U.S. 753, the court concluded that the constitutionality of a warrantless search of a container found in an automobile depends on whether the owner possesses a reasonable expectation of privacy in its contents. Applying that test, the court held that the warrantless search of the paper bag was valid but the search of the leather pouch was not. The court remanded for a new trial at which the items taken from the paper bag, but not those from the leather pouch, could be admitted.

Issue:
Pursuant to PC an arrest was made from an automobile, may the police constitutionally search closed containers within the trunk of the automobile?    

Ruling:
The judgment of the Court of Appeals is reversed. The case is remanded for further proceedings consistent with this opinion.        

Holding:
When the police have probable cause to search a car for contraband, they may search the entire car and any containers found within the car that could contain evidence of the crime.
 
Rationale:

  1. Reasonable Observation: Police called in plates and they matched the description
  2. Reliable Outsource Information: Informant saw the drug deal happening (credibility, basis of knowledge?)
  3. Commit/Committed a crime
  4. Evidence may be found

 

Conclusion: If the probable cause justifies the search, it justifies every part of the vehicle and its contents that may contain the object of the search.

 

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