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United
States v. Edwards (1974)
United States Supreme Court
Author: P Mac Daddy
Procedure: The defendant was
convicted based on paint chip evidence recovered from his
clothing while he was in the county jail, but the court of
appeals reversed the conviction ruling that the officers needed a
warrant before taking the clothing of the defendant who was
spending a nice weekend in the county jail!
Facts: Shortly after 11pm on May 31,
1970, the defendant/respondent Edwards was arrested on suspicion
of attempting to pull off a nighttime burglary of a Lebanon Ohio
post office. The failed burglar attempted to gain entry with a
pry bar or cat claw type of tool to break in but all it did was
cause the paint to chip away in the area of the window where
failed entry was attempted. The morning after his arrest, the
police officers bought new clothing for the defendant and they
took his original clothes and found paint chips on the
defendant's clothing which linked him to the crime. He was
convicted for the failed Port Office heist and the appeals court
reversed the conviction saying the seizure of the clothing,
though occurring while the defendant was detained in jail still
constituted a warrantless seizure under the Fourth Amendment.
Issue: Did the officers need a
warrant to search the clothing of the defendant about 10 hours
after he was lawfully arrested?
Reasoning: (White) No, The
court ruled that "once a defendant is lawfully arrested and
is in custody, the effects in his possession at the place of
detention that were subject to search at the time and place of
his arrest may lawfully be searched and seized without a warrant
even though a substantial period of time has elapsed between the
arrest and subsequent administrative processing on the one hand
and the taking of the property for use as evidence on the
other." The police in this situation did not have a suitable
set alternate of clothing for Edwards, so they allowed him to
remain in the clothes in question until a set could be procured
the next morning. They could have had him surrender his clothes
the minute he arrived and he’d stay the first night in the
cell in nothing but his birthday suit, but they found an
alternate set of clothes before taking his. Once under legal
police custody, the control of such articles is surrendered to
the coppers.
Dissent: (Douglas, Stewart, Brennan
& Marshall) under the facts of this case, I am unable to
agree with the court’s holding that this search was incident
to Edwards’ custodial arrest. The search here occurred fully
10 hours after he was arrested, at a time when the administrative
processing and mechanics of the arrest had long come to an end.
His clothes were not seized as part of an inventory of a prisoner’s
effects, nor were they taken pursuant to a routine exchange of
civilian clothes for jail garb. And the considerations that
typically justify a warrantless Search incident to a lawful
arrest were wholly absent here. This amounts to a massive
invasion of privacy under the 4th Amendment.
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