Table of Contents
Introduction to the Case
The Supreme Court case of Carroll vs. the United States is the case number, 267 US 132. This case was argued in court on December 4th, 1923. It was later restored to court for its reargument on January 28th, 1924. On March 14th, 1925, the case was reargued and henceforth decided on March 2nd, 1925 (Grant, 1941). The plaintiff in the case was the United States, represented in court by later Attorney General, Mr. James M. Beck. The Plaintiffs were George Carroll and John Kiro, represented in court by the lead counsel Thomas E. Atkinson. He was assisted by the lawyer Clare J. Hall. The case was heard by nine judges of the Supreme Court: William Howard Taft, Louis D. Brandeis, Joseph McKenna, Edward Terry Sanford, James Clark McReynolds, Pierce Butler, George Sutherland, and Willis Van Davante Jr. Meanwhile Justice Howard Taft was delivering the ruling, two justices, George Sutherland and James Clark Reynolds disagreed with the decision. The hearing of the case was placed in Washington, D.C. The Supreme Court decision in Carroll vs. the United States formed a foundation, upon which law enforcement officers obtained the legal authority to conduct unwarranted searches on automobiles. All the subsequent statutes bore the connotation of a probable cause in very comprehensive terms.
Summary of the Case
The case involved the application of the National Prohibition Act and the Fourth Amendment. The National Prohibition Act defines it as a misdemeanor for any law enforcement officer to conduct a search in a private dwelling without first obtaining and proving the following fact. They have a search warrant; and without a probable cause of the said property or dwelling being involved in unlawful practices. The probable cause is a belief by law enforcement officers that reasonably emanates from circumstances known to the law enforcer(s) that the automobile contains the illegal liquor under the Prohibition Act (Katz, 1983). The Congress has intended to make clear the intent of a law enforcement officer by introducing a necessity of the probable cause while enforcing the Prohibition Act.
The Fourth Amendment denounces any searches that contravene the public interest and those of private citizens as unreasonable. Therefore, in opinion of the Supreme Court, when the police seize and search the vehicle carrying the illegal liquor as mandated by the Prohibition Act. They do not violate the Fourth Amendment as long as they do so upon the probable cause (Grant, 1940). Various Acts of the United States were invoked to interpret the Fourth Amendment as possessing some necessary indifference for contraband substances stored in a dwelling, an automobile or in a private house. The police must conduct the unwarranted search to obtain evidence in time for a successful prosecution. Hence, the section 26, Title II, of the Prohibition Act, allows a law enforcement officer to arrest any person caught while transporting intoxicating liquor in a vehicle. In fact, the section makes it a duty for the police officer to do so (McCauliff, 1982). The confiscated liquor may be destroyed or the court shall order a public sale.
- The Supreme held that seizures and destruction of illegal liquor, the forfeiture of the automobile, and the apprehension of a transporter are incidental as opposed to depending on the person’s right to privacy (Collins & Hurd, 1984).
- Whether or not an offender has committed a first, second or felony is not a test of validity for the seizure of an automobile, the arrest of the offender and confiscation of other related property (p.189).
- An officer with the probable cause that the transportation involves illicit liquor has the legal authority to stop and conduct an unwarranted search of the vehicle (p.190).
- The section 26 was enacted by the Congress by construing that it had been consistent with the Fourth Amendment.
- The fact that the contraband liquor used as the evidence after justification of the probable cause was not returned to defendants does not substantially influence a reversal of the conviction.
- Grand Rapids, which is based in Michigan, about 152 miles from Detroit, is located near an international border where illegal transportation of contraband is likely to be high.
Effects of the Case on Ruling towards Criminal Justice or Enforcement
The ruling of the Supreme Court changed the way law enforcement agencies approached the search exception for moving cars to the warrant requirement. The Supreme Court has continued to adopt the same position in similar cases. In fact, the precedent set in this case was subsequently popularized as the Carroll doctrine. Moving cars retained their Constitutional protection for privacy interests (p.193). However, the court observed that the mobility of cars exempted them from the traditional warrant requirements. Hence, cars do not have to be broadly protected. Preceding cases of the same nature faced the same fate, especially when in the enforcement of the prohibition Act. In 1931, the case involving a car that had been searched when parked was upheld by the Supreme Court based on the precedent (p.193). The Court ruled that the police could not know or tell when the car would be moved. In 1948, the same precedence was used to apply an automobile limit on vehicles being under investigation for violating any other federal law. It includes also the Prohibition Act. In 1949, the precedent was used to uphold the search of cars by the police as long as they had the probable cause. It cast the vehicle’s involvement in violating a federal law or any other illegal activity (p.198).
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The 1960s was the period when the court precedence set by this case had been entrenched in the justice system (Shapiro, 1991). The precedent granted the police the status of federal authorities authorized by the law to conduct searches on automobiles without a warranty, but with a sufficient probable cause (p.45). By calling them Federal authorities, they could arrest and conduct a warrantless search of car for a period of a week, since it was deemed to be under government confiscation (Player, 1970). Thus, the evidence collected from the warrantless search is admissible in court. The police do not, therefore, require a search warrant to collect paint samples from any car public in a public place.
During the trial in the United States vs. Chadwick, the case articulated on a wide scale. In fact, the case almost became a basis of the entire ruling (p.269). The justices brought up the ruling arguing that the person’s right to privacy. It has become less once their case involved an automobile than in other enclosures such as houses or a locked luggage. Since the ruling in Chadwick’s case, the Supreme Court has continuously enlarged an exception on automobiles beyond the ruling that set the Carroll doctrine. For example, in 1978, the court went further to restrict passengers from objecting a warrantless search on a vehicle they are boarding on as long the police have the probable cause (p.269).
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Since the ruling in the Carroll vs. the United States, property concepts have gradually become more closely associated with the Fourth Amendment than privacy rights (Grant, 1940). It explains why the court went ahead to rule in the 1980s that warrantless police officers with the probable cause are legally allowed to search even the containers in it (p.359). With some time, since the ruling of Justice Taft, the public in the United States have continuously had low expectations on their rights to privacy. It is related to the case when it comes to warrantless searches by the police.
The decision of the Michigan Court of Appeals in Michigan vs. Thomas is a manifestation that Carroll vs. the United States allowed the police to have a warrantless search of a vehicle (Davies, 1999). In enforcing the law, the police are actually more compelled to prove and express the probable cause rather than bothering about obtaining a search warrant. In Michigan vs. Thomas, the police arrested a person for violating traffic law. They impounded his vehicle. When the vehicle was still in the hands of the police, they found two bags of marijuana inside the vehicle (p.551). Another officer decided to further search the vehicle using the probable cause arising from the discovery of marijuana in the vehicle’s glove compartment. The Court of Appeal decided to overturn Thomas conviction based on the fact that the vehicle had been not moving while in custody of the police (p.552). When the case was heard by the Supreme Court, it rejected the decision of the Michigan Court of Appeal (555). In the ruling, the Supreme Court held that the police could still search an immobile vehicle in their custody as long as they had the probable cause of the vehicle’s involvement in crime (p.559). The probable cause, in this case, arose from the fact that the police had found marijuana in the car.
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The Fourth Amendment and the Prohibition Act have an interpretational conundrum especially on determining the circumstances. Such ones dictate an unwarranted search of automobiles. The legal controversies revolved around the following issues as the bones of contention: 1) when and how law enforcement officers can prove or express the probable cause; 2) the admissibility of evidence confiscated from arrested persons before the court; 3) the extent to which the enforcement of the Prohibition Act may violate the Constitutional rights of private citizens as per the provisions of the Fourth Amendment; and 4) if the police really represent the federal authorities in respect to what is spell out in the Prohibition Act. The precedent set by the Supreme Court in Carroll vs. the United States case has begun an era where the police gradually have acquired the authority to conduct unwarranted searches on vehicles as long as they have the probable cause. Perhaps, the only burden of proof the police have is in an event they have not been probable. However, in most cases, the probable cause invoked by law enforcement officers normally comes out right because it is hardly based on flimsy suspicion. When the police decide to conduct an unwarranted search, they depend on reliable intelligence information of the vehicle’s involvement in transporting the contraband liquor. Furthermore, the Prohibition could not have been adopted by the Congress if it had any provisions violating any Constitutional provisions on the rights of private citizens.
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