Florida v. Jimeno, 500 U.S. 248 (1991)

Facts

Officer overheard what he thought was a narcotics transaction and followed Jimeno.  He pulled Jimeno over for failure to stop and asked for consent to search the vehicle for narcotics.  Jimeno consented and the officer found cocaine inside a folded brown paper bag.

Procedural History

Jimeno moved to suppress the cocaine on the ground that his consent to search the car did not extend to the closed paper bag inside the car.  The trial court granted the motion.  The Court of Appeals and Florida Supreme Court affirmed.

Issue(s)

Did the lower courts err in finding that consent to search the car did not extend to sealed containers within the general area agreed to by the defendant?

Holding(s)

Yes.

Reasoning/Analysis

The Court found that Jimeno granted the officer permission to search the car and did not place any explicit limitation on the scope of the search.  We think that it was objectively reasonable for the police to conclude that the general consent to search Jimeno’s car included consent to search containers.  We see no reason for requiring officers to separately request permission to search each container.

Judgment/Outcome

The Court reversed and remanded the judgment of the lower courts.