Chambers v. Maroney

''Chambers v. Maroney'', 399 U.S. 42 (1970), was a United States Supreme Court case in which the Court applied the ''Carroll'' doctrine in a case with a significant factual difference—the search took place after the vehicle was moved to the stationhouse. The search was thus delayed and did not take place on the highway (or street) as in Carroll. After a gas station robbery, a vehicle fitting the description of the robbers' car was stopped. Inside were people wearing clothing matching the description of that worn by the robbers. They were arrested, and the car was taken to the police station where it was later searched.

Opinion of the Court

The Court first held that the search could not be sustained as a search incident to arrest (SITA). It quoted at length from Carroll that a search of a movable vehicle is treated differently under the Fourth Amendment because the mobility of the vehicle alone can easily defeat the warrant requirement. If there is probable cause to believe the vehicle contains criminal evidence and there exist exigent circumstances where the vehicle can be removed from the jurisdiction, a warrantless search would be reasonable. It made no constitutional difference here that the search followed the seizure because the probable cause which developed on the street still existed at the station house (where the vehicle was impounded).''Chambers'', 399 U.S. at 52. Compare (overruled on other grounds by and diverged from by (a delayed seizure of clothing from an arrestee was not an unreasonable search), and (delay of mail in transit to allow probable cause to develop). For this purpose, it is significant to note that the automobile exception and the SITA doctrine are quite different.

Aftermath

Companion cases, including ''Perini v. Colosimo'',399 U.S. 519 (1970). ''Crouse v. Wood'',399 U.S. 520 (1970). ''Hocker v. Heffley'',399 U.S. 521 (1970). and ''Kelley v. Arizona'',399 U.S. 525 (1970). were vacated in ''per curiam'' opinions and respectively remanded to the Sixth Circuit, Tenth Circuit, Ninth Circuit, and Arizona Supreme Court, "for further consideration in light of ''Chambers v. Maroney''". In each case the ''per curiam'' opinion noted that Justice Harlan would have remanded "for the reasons stated in his separate opinion in ''Chambers''".

See also

*List of United States Supreme Court cases, volume 399

References

Further reading

Chambers is discussed in:
*Note, 75 Dick L Rev 511 (1971);
*Note, 46 Ind L J 257 (1971);
*Comment, 47 Notre Dame Law 668 (1972);
*Note, 7 Tulsa L J 197 (1971);
*Note, 23 Vand L Rev 1370 (1970).
*Heisse, Warrantless Automobile Searches and Telephonic Search Warrants: Should the ''Automobile Exception'' be Redrawn?, 7 Hast Const L Q 1031 (1980).

External links

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{{US4thAmendment, warrantexceptions, state=expanded

1970 in United States case law
United States Supreme Court cases
United States Fourth Amendment case law
United States Supreme Court cases of the Burger Court