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Carroll v. United States

From lawbrain.com

Carroll v. United States, 267 U.S. 132 (1925), was a criminal procedure case decided by the United States Supreme Court concerning the “automobile exception” which deals with warrantless searches of cars.

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Contents

Summary of Case Facts

An undercover officer attempted to buy alcohol, during Prohibition, from Carroll. That transaction was never completed. Months later, the same officer recognized Carroll and his vehicle as it was traveling along a Michigan highway. The officer pursued Carroll, pulled him over, and conducted a warrantless search of his vehicle. Inside, officers found sixty-nine quarts of whiskey. The United States convicted Carroll of violating the Volstead Act and the Eighteenth Amendment. Carroll appealed, citing the warrantless search of the automobile as a violation of the Fourth Amendment.

Issue

May an automobile be searched without a warrant?

Holding and Law

The court upheld warrantless searches of automobiles when probable cause existed for such a search – i.e. reasonable belief that the automobile to be searched contains evidence of a crime. The court noted the differences between automobiles and fixed structures such as buildings. Automobiles are mobile by nature and can be hidden or moved out of the jurisdiction before a warrant could be procured. As such there are times when requiring a warrant to search a vehicle may be impracticable. As applied in this case, the court affirmed Carroll’s conviction, holding that the officer had probable cause to search his vehicle.

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