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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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