Coolidge v. New Hampshire
Citation: 403 U.S. 443 (1971)
Facts
Police investigating a murder obtained a warrant from the state attorney general (not a neutral magistrate). They searched Coolidge’s car parked in his driveway and found incriminating evidence in plain view. The issue included both the validity of the warrant and the scope of the plain view doctrine.
Issue
(1) Is a warrant issued by a law enforcement official (the attorney general) valid? (2) Does the plain view doctrine permit seizure of evidence found during a search authorized by an invalid warrant?
Holding
(1) No — a warrant must be issued by a neutral and detached magistrate; the attorney general, as chief law enforcement officer, was not neutral. (2) The plain view doctrine requires that the discovery of the evidence be inadvertent (in plurality holding); because police knew the car would be there, discovery was not inadvertent.
Rule
Neutral magistrate requirement: A warrant must be issued by a neutral and detached magistrate — not by a law enforcement officer, even a senior one.
Plain view doctrine (Coolidge plurality): Evidence discovered in plain view during an otherwise lawful search may be seized without a warrant if: (1) the officer is lawfully present at the location, (2) the incriminating nature is immediately apparent, AND (3) the discovery is inadvertent. (Note: the inadvertency requirement was later eliminated in Horton v. California, 1990.)
Significance
- Reinforces the neutral magistrate requirement from Johnson v. United States
- The inadvertency requirement from the Coolidge plurality was repudiated in Horton v. California — plain view now requires only lawful presence + immediately apparent incriminating nature
- Important for automobile search doctrine: automobile exception requires probable cause; plain view requires immediately apparent incriminating nature