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Preston v. United States
Citations: 11 L. Ed. 2d 777; 84 S. Ct. 881; 376 U.S. 364; 1964 U.S. LEXIS 1578Docket: 163
Court: Supreme Court of the United States; March 23, 1964; Federal Supreme Court; Federal Appellate Court
The case involves John Brenton Preston, who, along with three others, was convicted for conspiracy to rob a federally insured bank, based largely on evidence obtained from a search of a motorcar. The Sixth Circuit Court of Appeals upheld the conviction despite arguments that both the initial arrest for vagrancy and the subsequent search violated the Fourth Amendment. The Supreme Court granted certiorari to review the case. The events began when police received a complaint about three suspicious men in a parked car. Upon arrival, officers found Preston and his companions, who provided unsatisfactory explanations for their presence. All admitted to being unemployed and had very little money. They were arrested for vagrancy, searched for weapons, and taken to police headquarters. Although the car was not searched at the time of arrest, it was later towed to a garage, where officers conducted a search and found loaded revolvers and other incriminating items in the trunk. A companion of Preston later confessed intentions to rob a bank, leading to federal involvement. The case raised Fourth Amendment concerns regarding the legality of the search and seizure of evidence. The Court noted that searches by state officers are evaluated under the same standards as federal searches, emphasizing that any search of a motor vehicle must adhere to the reasonableness requirement of the Fourth Amendment for the evidence to be admissible in court. In Brinegar v. United States, the Supreme Court emphasizes that searches of movable vehicles, like motorcars, cannot be treated the same as searches of fixed structures such as homes. While a search of a vehicle may sometimes be reasonable where a house search is not, the overarching standard remains the reasonableness of the search. An exception to the requirement for a search warrant exists when a search is conducted incident to a lawful arrest, allowing officers to search the arrested individual and items within their immediate control for weapons or evidence. However, this right does not extend to searches conducted remotely in time or location from the arrest. In this case, although the initial search of the car was permissible due to the valid arrests or probable cause of theft, the subsequent search occurred later and at a different location—after the individuals were in custody and the car was secured—eliminating any immediate threat or risk of evidence destruction. Consequently, the search was deemed too remote to qualify as incidental to the arrest, thus violating the Fourth Amendment's reasonableness standard. The evidence obtained from the warrantless search was ruled inadmissible, leading to the reversal and remand of the case.