Florida v. Jimeno
Citation and Court
500 U.S. 248 (1991) — Supreme Court of the United States
Facts
A Miami police officer stopped Jimeno’s car for a traffic infraction and told Jimeno he suspected him of carrying drugs. Jimeno consented to a search of his car. An officer found a folded paper bag on the floorboard, opened it, and discovered cocaine. Jimeno argued that consent to search the car did not include consent to open closed containers within the car.
Issue
Does a suspect’s consent to search his car for drugs extend to closed containers within the car that could reasonably contain drugs?
Holding
Yes; a general consent to search a car for drugs reasonably extends to closed containers within the car that could reasonably hold the object of the search (drugs), absent any explicit limitation by the suspect.
Rule / Doctrine
The scope of a consent search is measured by objective reasonableness—what a typical reasonable person would have understood by the exchange between the officer and the suspect. General consent to search a vehicle for drugs permits opening of closed containers within the vehicle that could reasonably contain drugs, unless the consenting person expressly limits the scope of the search.
Significance
Florida v. Jimeno establishes the objective-reasonableness standard for interpreting the scope of a consent search, allowing officers to search containers within a consented-to area as long as a reasonable person would understand the consent to extend that far. It must be read alongside cases on the scope of consent and the ability to limit or revoke consent.