Rawlings v. Kentucky
Citation and Court
448 U.S. 98 (1980) — Supreme Court of the United States
Facts
Rawlings placed controlled substances in his companion Cox’s purse for safekeeping. When police searched Cox’s purse without her valid consent, they found the drugs. Rawlings immediately claimed ownership of the drugs to protect Cox but then moved to suppress on the ground that the search of her purse violated his Fourth Amendment rights.
Issue
Whether a person who owns contraband stored in a companion’s purse has a legitimate expectation of privacy in the purse sufficient to challenge its search.
Holding
No; Rawlings lacked standing to challenge the search of Cox’s purse because he had no reasonable expectation of privacy in the purse itself, and the ownership of the items inside was insufficient to confer standing.
Rule / Doctrine
Under Rakas v. Illinois, the Fourth Amendment inquiry focuses on the defendant’s personal rights in the area searched, not the items found there. One who stores property in another’s container — especially under hasty, temporary circumstances — does not thereby acquire a reasonable expectation of privacy in that container. Ownership of contraband found during a search cannot itself supply standing to challenge the search of the container in which it was stored.
Significance
Confirmed that ownership of seized items alone does not confer standing to challenge an allegedly unlawful search of the container in which those items were found. Defendants must show a personal privacy interest in the place searched, not merely in the objects discovered there.