United States v. Chadwick, 433 U.S. 1 (1977)

Facts

Amtrak officials noticed a footlocker was suspicious and alerted DEA agents in Boston.  When arriving in Boston, the police dog signaled the presence of a controlled substance without alerting Machado and Leary.  Chadwick met Machado and Leary and the three went to Chadwick’s car, when they were stopped.  The footlocker was taken with the three arrestees to the federal building and was searched 1.5 hours after the arrests.

Procedural History

Respondents moved to suppress the marijuana obtained from the footlocker and the District Court held that the footlocker was not part of the area from which respondents might gain possession of a weapon or destructible evidence.

Issue(s)

Did the District Court err in suppressing the evidence obtained from the footlocker as not being within the area of gaining possession?

Holding(s)

No.

Reasoning/Analysis

The Court found that to safeguard himself and others, it has been held reasonable for the arresting officer to conduct a prompt, warrantless search of the arrestee and the area within their immediate control.  Warrantless searches of luggage or property seized at the time of an arrest cannot be justified as incident to that arrest wither if the search is remote in time or place from the arrest.

Judgment/Outcome

The Court affirmed the judgment of the District Court.