United States v. Robinson
Citation: 414 U.S. 218 (1973)
Facts
Robinson was lawfully arrested for a traffic offense (driving with a revoked license). During a search incident to arrest, the officer found a crumpled cigarette package in Robinson’s breast pocket. The officer opened the package and found heroin-filled gelatin capsules. Robinson moved to suppress.
Issue
May a police officer conduct a full search of an arrestee’s person — including containers on the person — without any particularized suspicion of weapons or evidence?
Holding
Yes. A lawful custodial arrest justifies a full search of the person as a matter of course, without any additional justification. The officer need not identify a specific reason to search beyond the arrest itself.
Rule
Full search incident to custodial arrest: When a police officer makes a lawful custodial arrest, the officer may conduct a full search of the person as a matter of course — including containers on the person — without articulating any specific justification beyond the fact of the arrest. The rule is categorical, not dependent on case-by-case analysis of the need to search.
Significance
- Establishes the bright-line rule that a custodial arrest alone authorizes a full personal search
- Distinguished from Terry stops: a stop-and-frisk permits only a pat-down for weapons; a custodial arrest permits a full search
- Riley v. California creates an exception for cell phones — a warrant is required to search a cell phone found on an arrestee
- The arrest must be custodial (taking person into custody) — traffic citations without custody do not authorize a full search (Knowles v. Iowa)