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United States v. Robinson | 414 U.S. 218 (1973)
Imagine you commit a minor traffic offense and are arrested by a police officer. The officer conducts a full search of your person, including reaching into your pockets and opening closed containers that you possess. Is such a search lawful or does it violate the Fourth Amendment? The Supreme Court addressed this question in United States versus Robinson.
A police officer in Washington, D.C., saw Willie Robinson driving his car and, based on a prior encounter, knew that Robinson lacked a valid driver’s license. The officer stopped Robinson’s car and arrested him for driving with a revoked license. After arresting Robinson, the officer patted him down. The officer then put his hand in Robinson’s coat packet and pulled out a cigarette pack. The officer opened it and saw what he recognized as heroin.
A federal grand jury indicted Robinson for possession of heroin. Robinson moved to suppress the heroin, arguing that the officer had unconstitutionally searched his pocket and the cigarette pack without probable cause to believe that the search would yield evidence or a weapon. The district court denied the motion, reasoning that the arresting officer’s search of Robinson’s pocket and the cigarette pack was a valid search incident to arrest, an exception to the Fourth Amendment’s probable cause and warrant requirements. Robinson then had a jury trial, at which he was convicted.
On appeal, the United States Court of Appeals for the District of Columbia reversed Robinson’s conviction.
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