United States v. Robinson, 414 U.S. 218 (1973)

Facts

Robinson was stopped by Jenks for operating a motor vehicle after the revocation of his permit.  Robinson and the occupants emerged from the vehicle and Jenks informed Robinson he was under arrest.  While patting Robinson down, Jenks felt an object in the coat, which he removed and discovered was a crumpled cigarette pack.  Jenks then opened the cigarette pack and discovered gelatin capsules of heroin.

Procedural History

The heroin seized from Robinson was admitted as evidence in his trial and Robinson was convicted.  The Court of Appeals reversed.

Issue(s)

Was the officer’s search of the crumpled cigarette package, which Jenks admitted he did not know what was inside, a violation of the Fourth Amendment?

Holding(s)

No.

Reasoning/Analysis

The Court found that the Court of Appeals holding that the officer may only conduct a limited frisk, per Terry v. Ohio, was incorrect because Terry does not carry over to a probable cause arrest.  The Court also disagreed with the Court of Appeals finding that a stop for driving on a suspended license is less likely to discover weapons than a different stop.  The Court found that in the case of a lawful custodial arrest, a full search of the person is not only an exception to the warrant requirement of the Fourth Amendment, but is also a reasonable search under that Amendment.

Judgment/Outcome

The Court reversed the judgment of the Court of Appeals.