United States v. Chadwick
Citation and Court
433 U.S. 1 (1977) — Supreme Court of the United States
Facts
Federal agents observed Chadwick and associates load a double-locked footlocker onto a train. Suspecting it contained drugs, they arrested Chadwick at the station. An hour later, without consent or a warrant, they opened the footlocker at the federal building and found marijuana.
Issue
Whether the warrantless search of a closed, locked container after it has been lawfully seized but removed to a secure environment is constitutional under the automobile exception or the search-incident-to-arrest exception.
Holding
No; the warrantless search of the footlocker violated the Fourth Amendment. The automobile exception does not apply to containers simply because they were in a vehicle; once the container is secured and there is no exigency, a warrant is required.
Rule / Doctrine
The automobile exception is justified by vehicles’ mobility and reduced expectation of privacy, but a locked footlocker has greater privacy expectations than a vehicle’s cargo area. Once secured and at no risk of mobility, the container must be searched pursuant to a warrant. The search-incident-to-arrest exception also did not apply because the footlocker was not in the area of the arrestee’s immediate control at the time of the search.
Significance
Established that containers retain stronger Fourth Amendment protection than vehicles, requiring a warrant to search once secured. Subsequent cases — particularly California v. Acevedo — substantially qualified Chadwick when containers are found in vehicles during an automobile exception search.