United States v. Chadwick

433 U.S. 1 (1977)

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Nature of the Case

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Facts

Machado and Leary (Ds) were observed loading a suspicious footlocker on an Amtrac train. It was leaking talcum powder, and Machado matched a profile used to spot drug traffickers. Railroad officials reported the incident, and upon arrival in Boston, federal narcotics agents were on hand and used a trained police dog, and it signaled drugs in the footlocker. Eventually, Ds moved the locker to Chadwick's car waiting outside, and all three were apprehended. The parties were taken into custody, and the keys to the locker were obtained. There was no reason to believe that the locker contained explosives or other inherently dangerous contraband. There were no exigent circumstances present that would allow an immediate search of the footlocker. An hour and a half later the locker was opened, and marijuana was found in the locker. Ds moved to suppress the evidence, and the government countered by using the automobile exception and a search incident to a lawful arrest and that the Fourth Amendment did not apply to persons only places. The court ruled that the footlocker and Chadwick's auto were merely coincidental and that the double-locked 200-pound footlocker was not part of the area from within which Ds might gain possession of a weapon or destructible evidence.