Carroll v. United States

267 U.S. 132 (1925)

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Nature of the Case

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Facts

Undercover officers first met Ds in Grand Rapids. The officers said they wanted to buy 3 cases of whiskey. Ds left and said they would return in 30-45 minutes. The left and returned and said they couldn’t get it but could deliver them the next day. The officers took note of the license number on their car, an Oldsmobile roadster. Ds left going to Grant Rapids to get liquor. Of the three one returned and told the officers they could not acquire the liquor but could get it the next day. Ds did not return. The officers knew that the highway from Detroit to Grand Rapids was used for smuggling alcohol. The officers once again saw the same car with Ds in it a few months later when they were patrolling the highway. Ds were driving towards Detroit. The officers gave chase and caught up to Ds. Ds were pulled over, recognized the officers, and the officers searched the car without a warrant. Liquor was discovered. The officers had no idea they would see Ds again. When they saw them again in the same car on that particular highway they believed they were carrying liquor; and hence the search, seizure, and arrest. Ds were arrested and tried. The trial court admitted in evidence two of the 68 bottles, one of whiskey and one of gin, found by searching the automobile. Ds claimed the search and seizure were in violation of the Fourth Amendment, and therefore that use of the liquor as evidence was not proper. Ds moved that all the liquor seized be returned. That motion was denied. The court held that the right to search and the validity of the seizure was not dependent on the right to arrest, but were dependent on the reasonable cause the seizing liquor agents had for their belief that the contents of D's automobile were illegal. The court found that the agents had ample reason to believe Ds' vehicle contained illegal liquor because Ds were known to transport liquor in that vehicle, were recognized by the agents, and were on a route known for illegal liquor traffic. Those circumstances provided sufficient probable cause to search the vehicle. Ds appealed and argued that the officers did not have probable cause to search.