California v. Acevedo
Citation: 500 U.S. 565 (1991)
Facts
Police observed Acevedo place a paper bag (which they had reason to believe contained marijuana) into the trunk of his car. When he drove away, they stopped him and searched the trunk and the bag without a warrant.
Issue
When officers have probable cause to believe a container placed in a car’s trunk contains contraband, may they search the container without a warrant under the automobile exception?
Holding
Yes. Under the automobile exception, police may search a container within a car without a warrant if they have probable cause to believe the container holds contraband or evidence, even if their probable cause is specific to the container.
Rule
Acevedo rule (container in vehicle): The automobile exception allows a warrantless search of a closed container in a vehicle whenever officers have probable cause to believe the container holds contraband or evidence — regardless of whether the probable cause encompasses the whole vehicle or only the specific container.
This resolved the anomaly from United States v. Chadwick (warrant required to search luggage in vehicle) by extending the automobile exception to containers where probable cause specifically attaches to the container.
Significance
- Unified the automobile exception: if there is probable cause — whether to the whole car or to a container in the car — police may search without a warrant
- Overruled the Chadwick/Sanders line requiring warrants for containers (as applied to containers in vehicles)
- Simplified the rule for officers in the field
- Distinguishes from home searches: in a home, a container still requires a warrant even if there is probable cause specific to the container