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Illinois
v. Lafayette:
United States Supreme
Court, 1983.
Statement of the Case:
Arrested theatre altercator is challenging
a search of his man purse when he was arrested and
the bag was inventoried/searched back at the station, leading to
his conviction for possession of a controlled substance.
Procedure:
Lower courts ruled this to be an
unconstitutional search.
Facts:
Officer arrested disorderly theatergoer
and took him to the station. He had a purse-type bag.
When he made the ? empty his pockets, he also searched the bag
and found 10 amphetamine pills.
Issue:
Whether it violates the 4th
Amendment for police to search the personal items of a person
under lawful arrest as part of a routine administrative procedure
at a police stationhouse, incident to booking and jailing the ?.
Procedural Result:
Judgment reversed for the State.
Holding:
The 4th Amendment does not
prevent the police from searching the personal items of a person
under lawful arrest as part of a routine administrative procedure
at a police stationhouse, incident to booking and jailing the D.
Reasoning:
- Inventory search is
not a search, but an incidental administrative step
following arrest and preceding incarceration.
- At a stationhouse,
it is proper to remove and list inventory from the person
being jailed for the following reasons:
- Makes a
list of the ?s possessions so that false
claims are not filed, and theft does not occur.
- ? may
injure himself or others with dangerous objects
that are easily concealed.
- May assist
police in verifying the identity of the arrested
party.
- Police do not need
any particular fear, as this is a bright-line rule, like
in Robinson.
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