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Chambers v. Maroney:
United States Supreme
Court, 1970.
Statement of the Case:
Chambers, arrested after identified for
robbing a gas station, contends that evidence seized from within
the vehicle, in which he was riding at the time of his arrest, is
inadmissible in court as the vehicle was searched without a
warrant and the car was only searched after being driven to the
police station.
Procedure:
Lower courts allowed the evidence.
Facts:
A 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.
Issue:
Whether it is a violation of the 4th
amendment to search the Ds vehicle at another place, such
as a police station, without a warrant incident to that arrest.
Procedural Result:
Affirmed for State.
Holding:
It is NOT a violation of the 4th
amendment to search the ?s vehicle at another place, such
as a police station, without a warrant incident to that arrest,
so long as there was probable cause to search it at the place of
arrest.
Reasoning:
- Court distinguishes
between the home and a vehicle, as a machine capable of
conveyance can be searched in a way that would be a
violation at a home.
- 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 offend against 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.
- There is really no
difference between making the search on the spot, or at
the station that night.
Concurring/Dissenting:
- The officers should
preserve evidence and make the search possible, BUT
- Taking the car to
the station shows a lack of exigent circumstances.
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