Carroll v. United States
Citation: 267 U.S. 132 (1925)
Facts
Federal prohibition agents stopped Carroll’s car on a public road and searched it without a warrant, finding liquor hidden in the cushions. The agents had probable cause to believe the car was carrying illegal liquor based on prior dealings with Carroll.
Issue
May police search a vehicle without a warrant when they have probable cause to believe it contains contraband?
Holding
Yes. The inherent mobility of automobiles creates exigent circumstances that justify a warrantless search when officers have probable cause to believe the vehicle contains contraband or evidence of a crime.
Rule
Automobile exception: A warrantless search of a vehicle is permissible under the Fourth Amendment if officers have probable cause to believe the vehicle contains contraband or evidence of a crime. The mobility of vehicles (and, later, the reduced expectation of privacy in vehicles) provides the justification for the exception.
Significance
- Foundational case establishing the automobile exception to the warrant requirement
- Later cases extended and refined the exception:
- United States v. Ross (1982): if there is probable cause to search the whole car, officers may search every part of the vehicle and any container that might contain the object of the search
- California v. Acevedo: officers may search a closed container in a car if they have probable cause to believe it contains contraband, even if probable cause is limited to the container alone
- Arizona v. Gant: search incident to arrest of vehicle is more limited; automobile exception (Carroll) remains broader
- The automobile exception now rests on both mobility and reduced expectation of privacy