United States v. Robinson: 
United States Supreme Court, 1973. 

Statement of the Case:

      Robinson, speeder, is challenging a search of his body when he was lawfully arrested for speeding but a search of his body turned up no weapons and a crumpled pack of cigarettes which he contends the officer illegally opened, finding heroin.

Procedure:

      Trial court convicted the ?, and the appellate court reversed.

Facts:

      An officer spotted the respondent driving the car and officer had probable cause that respondent was driving the car after the revocation of his license.  Officer stopped the respondent and lawfully arrested him.  Officer patted down the person of the respondent and felt a cigarette packet and he further searched the packet and found heroin capsules.

Issue:

      Whether it violates the 4^th Amendment to search inside personal items when arresting someone when it is too small to turn up conventional weapons (guns/knives) and there is really no need to find evidence for the arresting violation.

Procedural Result:

      Judgment reversed for the State.

Holding:

      It does not violate the 4^th Amendment to search inside personal items when arresting someone when it is too small to turn up conventional weapons (guns/knives) even though there is really no need to find evidence for the arresting violation.

Reasoning:

• Rule:  A search incident to a lawful arrest is a traditional exception to the warrant requirement of the 4^th Amendment. 
• Chimel held that it is reasonable for the arresting officer to search the person arrested in order to remove any weapons that the latter might seek to use in order to resist arrest or effect his escape and to preserve evidence on his person for later use at trial. 
• Also, a custodial arrest of a suspect based on probable cause is a reasonable intrusion under the 4^th Amendment that intrusion being lawful, a search incident to arrest requires no additional justification. 
  • The ? could have had a pin or razor in the cigarette pack, so it is reasonable that the packet was taken and checked.
• Based on these reasons, the Court held that a search of the arrestee incident to a lawful arrest is not only a valid exception to the warrant rule but it is also reasonable under the 4^th Amendment

Dissent:

• It was not necessary to take the packet because:
  • Traffic stop pat down showed that there were no big weapons on the ?.
  • No evidence needed to be preserved since the ? was arrested for a traffic, not narcotics, violation.

Additional Points: 

• Gustafson v. Florida:  ? contended search of a cigarette box found on his person was not reasonable because no regulation required he be taken into custody or searched.  Court found this case to be the same as Robinson. 
  
• Knowles v. Iowa:  When officer has the discretion to take someone into custody or just cite them in lieu of arrest (like in the traffic stop in this case), and they choose to just cite the offender, there is no right to a search, since the two rationales for searching (officer safety, and gathering losable evidence) are non-existent. 
  
• Because Atwater authorizes arrests for all minor traffic stops, an officer can avoid the stricture of Knowles by placing the minor offender under arrest.