The Law School Authority

Chambers v. Maroney Case Brief

Summary of Chambers v. Maroney (1970)
United States Supreme Court

Procedure: Petitioner convicted of robbery, sought review of a ruling from the United States Court of Appeals for the Third Circuit, which affirmed denial of his petition for writ of habeas corpus.

Statement of the case: D’s contends that evidence seized from within the vehicle, in which petitioner was riding at the time of his arrest, is inadmissible in court as the vehicle was searched without a warrant. That the court should suppress the fruits of a police search that links them to a string of lucrative gas station robberies! Wonder how many cans of Kodiak, those sons of bitches got?

Facts: service station was robbed by two men. Witnesses saw a blue compact station wagon circling the station during the day and saw the same car speed off after the robbery, and that four men were in the car with one wearing a green sweater. The service station attendant told the police that one of the men was wearing a green sweater and the other a trench coat. The car was stopped within the hour and the occupants were arrested. After the arrest the car was taken to the police station and searched without a warrant. Guns were found along with cards bearing the name of another service station attendant that was robbed two weeks ago. After a warrant search of Ds home, police found ammunition similar to that found in one of the guns taken from the station wagon that were hidden underneath a panel in the glove box!

Issue: Once an accused is under arrest and in custody, is a search made at another place without a warrant incident to that arrest?  This search took place at the scene of the stop as opposed to at a police impound yard.

Reasoning: (White) No. There is no doubt that the police were justified in their arrest of the occupants of the car as they fit the description given by witnesses at the crime scene. They also were justified in an immediate search of the car pursuant to that arrest. The right to search and the validity of a seizure are not dependent on the right to arrest but are dependent on the reasonable cause the seizing officer has for belief that the contents of the auto in violation of the law. Under these circumstances, either the search must be made immediately without a warrant or the car itself must be seized and held without a warrant for whatever period is necessary to obtain a warrant for the search. However, there was probable cause for the search and seizure of the car that was independent of that required for the arrest. The car could have been searched on the spot, it was not unreasonable to take the car to the station and search it there instead of searching it in the middle of a parking lot in the middle of the night, once the car was in the station there was little chance that any evidence would escape, but on the scene the cops had reason to believe the suspects were armed and had cash from the gas station stick up. This was more than a hunch, it was all the shit we’ve talked about in class and will again once we go over this case! The court used Carroll v. United States where the court had held that if the officers have probable cause to believe that incriminating evidence is hidden inside the car, they can search the car without a warrant. The court in the current case also stated that since the car was already seized, the greater harm was already done and now that the officers had probable cause to believe that there was evidence in the car, they had the right to search the car without obtaining a warrant. The conviction was affirmed.



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