Court: Supreme Court of the United States; July 6, 1976; Federal Supreme Court; Federal Appellate Court
Mr. Chief Justice Burger delivered the Court's opinion, reviewing the Supreme Court of South Dakota's judgment that local police violated the Fourth Amendment during a routine inventory search of a lawfully impounded vehicle. The vehicle was parked in violation of municipal ordinances in Vermillion, S.D. An officer issued a parking ticket around 3 a.m. and a second ticket later that morning, leading to the vehicle's towing to an impound lot. While inventorying the car's contents, police discovered marihuana. The respondent was later arrested for possession after the marihuana was retained by the police. His motion to suppress the evidence from the inventory search was denied, resulting in a conviction and a sentence of a $100 fine and 14 days' incarceration. On appeal, the South Dakota Supreme Court reversed the conviction, citing a violation of the Fourth Amendment. The U.S. Supreme Court granted certiorari and reversed the state court's decision. The Court differentiated between automobiles and homes regarding Fourth Amendment protections, citing the inherent mobility of vehicles and the reduced expectation of privacy in automobiles, which justifies a lesser standard for warrantless searches compared to homes or offices.
Law enforcement officials frequently interact with automobiles in their duties to ensure public safety, with much of this contact being noncriminal. Unlike homes, automobiles are subject to extensive governmental regulation, including inspections and licensing. Police routinely stop vehicles for violations such as expired tags or safety issues. The expectation of privacy in vehicles is lower due to their public nature; they are often not used as residences and their contents are visible during travel. The Supreme Court has recognized that vehicles are primarily for transportation. In performing "community caretaking functions," police may impound vehicles involved in accidents or those violating parking laws to maintain traffic flow and public safety. The authority to remove such vehicles is well-established. When impounding, police typically secure and inventory the vehicle's contents to protect the owner's property, safeguard against claims of lost items, and ensure officer safety. This procedure is vital for preventing theft or vandalism and also helps determine if a vehicle has been stolen. These practices are generally upheld by state courts, reflecting the localized nature of traffic regulation.
The Fourth Amendment's "reasonableness" standard has been upheld by numerous state courts, which have affirmed that inventory searches, even if classified as searches, are constitutionally permissible. Key cases include City of St. Paul v. Myles, State v. Tully, and People v. Trusty, among others. These courts recognize that standard police inventory procedures, such as examining a vehicle's glove compartment, are reasonable acts intended to secure property. Federal Courts of Appeals similarly endorse these procedures, affirming that when police take custody of a vehicle, it is reasonable to search it to itemize contents. The Fourth Amendment prohibits only unreasonable searches, which must be assessed based on the circumstances of each case rather than fixed rules. The Supreme Court has supported this view, emphasizing that not all searches require a warrant, but must be reasonable in context. In Cooper v. California, for instance, the Court validated an inventory search of an impounded vehicle, confirming the reasonableness of the search even when conducted in a criminal context.
A warrantless search of a vehicle can be justified under the caretaking function of police, even without probable cause, as established in several Supreme Court cases. The Court noted it would be unreasonable to deny police the right to search a vehicle in their custody for their protection. In Harris v. United States, evidence was deemed admissible from an inventory search where an officer found a registration card while securing the vehicle. Similarly, in Cady v. Dombrowski, a warrantless search of a towed vehicle was upheld to ensure community safety, based on the police's belief that a weapon might be present due to the incapacitated driver's status. The Court emphasized adherence to standard procedures to limit the scope of such searches. The case at hand involved the Vermillion police conducting a caretaking search of a vehicle lawfully impounded due to multiple parking violations, with valuables in plain view. The owner was not available to secure the items, justifying the inventory search. The Court concluded that the police actions were reasonable under the Fourth Amendment, aligning with established legal principles.
The South Dakota Supreme Court's judgment is reversed and the case remanded for further proceedings consistent with the opinion expressed. During the respondent's trial, an officer testified that the car was inventoried primarily for safekeeping due to past incidents of theft from impounded vehicles, despite the vehicles being locked. The officer described the impound lot as inadequately secured with a dilapidated wooden and wire fence.
The document references landmark cases indicating that a warrant is necessary for unconsented administrative entries into private properties, but clarifies that this requirement does not apply to automobile inspections for safety purposes. It cites statistics showing a significant number of vehicles towed by state officials without the need for probable cause. The text emphasizes that the reasonable standard for inventory searches differs from criminal investigations, and courts have generally ruled that search warrants are unnecessary in noncriminal contexts.
Additionally, it discusses the benign nature of police inventory procedures for vehicles in custody, noting that some courts have determined such inventories do not constitute searches under the Fourth Amendment. Although some courts have questioned this classification, the petitioner has abandoned claims that the inventory is exempt from Fourth Amendment scrutiny. The case of Cooper is referenced, where a car was taken into custody during a narcotics arrest, and the search occurred prior to the initiation of forfeiture proceedings, raising issues of certainty regarding such proceedings at the time of the search.
The police had no automatic reason to assume the defendant's automobile would be forfeited to the State, as no forfeiture proceedings were initiated. The California Court of Appeal indicated that limiting actions to a forfeiture statute was unwarranted. The legality of the inventory process was not contested; the officer was securing the vehicle from the elements, which justified opening the car. The inventory was deemed reasonable, as the officer's entry to secure visible property allowed for the exploration of the unlocked glove compartment, which was vulnerable to vandalism. The dissent's argument regarding "consent" misinterprets the inventory's purpose, which serves to protect both the vehicle owner and public interests, including safeguarding against claims of lost property and preventing vandalism that could lead to dangerous situations involving firearms or contraband.
