United States v. Place
Citation and Court
462 U.S. 696 (1983) — Supreme Court of the United States
Facts
DEA agents in Miami relayed information about Place, who was traveling with suspicious luggage, to DEA agents in New York. When Place arrived in New York, agents seized his luggage and held it for 90 minutes while awaiting a narcotics dog. The dog alerted; a warrant was obtained and drugs were found.
Issue
Whether the 90-minute seizure of Place’s luggage was an unreasonable seizure under the Fourth Amendment, and whether a canine sniff of luggage constitutes a search.
Holding
The 90-minute detention of the luggage was unreasonable and violated the Fourth Amendment; however, a trained narcotics dog’s sniff of luggage in a public place is not a “search” within the meaning of the Fourth Amendment.
Rule / Doctrine
A Terry-style investigative seizure of luggage is permissible, but only for a reasonable time and in the least intrusive manner. The 90-minute wait here was excessive and converted the seizure into a full seizure requiring probable cause. Separately, a dog sniff is not a search because it discloses only the presence or absence of contraband, not the contents of private compartments, and thus does not implicate a legitimate privacy interest.
Significance
Established two significant Fourth Amendment principles: (1) the temporal limits on Terry-style seizures of personal property; and (2) the rule that a trained narcotics dog sniff is not a Fourth Amendment search — a rule reaffirmed in Illinois v. Caballes (2005).