Robbins v. California (1980)
- Docket
- 80-148
- Decided
- 1980-01-01
Summary
Question: May police officers search closed containers found during a lawful, warrantless search of an automobile? Conclusion: No. Justice Potter Stewart delivered the opinion of the 6-3 plurality. The plurality opinion held that the automobile exception to the warrant requirement under the Fourth Amendment did not extend to closed and opaque containers found during the search. According to the plurality of the Court, the record in the case did not support the appellate court’s finding that Robbins did not have a reasonable expectation of privacy. Chief Justice Warren E. Burger concurred in the judgment of the Court. In an opinion concurring in the judgment, Justice Lewis F. Powell wrote that the careful manner in which the packages containing the marijuana were wrapped and sealed demonstrated Robbins’s intention to keep their contents private. However, he argued that the plurality opinion imposed too heavy a burden on police officers by requiring them to obtain a warrant to search every closed container found during a lawful, warrantless search of an automobile. Justice Harry A. Blackmun wrote a dissent in which he argued that the automobile exception to the warrant requirement should authorize police officers to seize and search any personal containers found within the vehicle. Justice William H. Rehnquist wrote a separate dissent in which he agreed with Justice Blackmun’s proposed rule. He also expressed opposition to the practice of excluding evidence obtained through impermissible means, especially with the Court’s extension of exclusionary rule to state law enforcement agencies in Mapp v. Ohio. He argued that the harshness of the rule created an unfair advantage for the suspects because it required police officers to not only understand the nuanced case law surrounding the Fourth Amendment, but also to make the correct decision instantly. Justice John Paul Stevens wrote a separate dissent in which he argued that the scope a lawful, warrantless search should include any container that a magistrate could authorize by warrant. As the police officers searched the car for evidence of contraband, the fact that the packages were tightly wrapped and sealed was of little consequence.