Carroll v. United States (1925)
Overview
Carroll v. United States established the automobile exception to the Fourth Amendment, allowing warrantless searches of vehicles under probable cause.
Federal agents searched a car suspected of transporting illegal liquor and discovered contraband without a warrant.
Ruling
The Supreme Court held that vehicles may be searched without a warrant if officers have probable cause to believe they contain evidence of a crime, due to their inherent mobility and reduced expectation of privacy.
Legal Principle Established
“If the search and seizure without a warrant are made upon probable cause, they are valid under the Fourth Amendment.”
Implication
This case created the foundation for modern vehicle search laws. Probable cause alone allows warrantless searches of vehicles, including locked compartments and containers.
Quick Guide
- No warrant required if there is PC that a vehicle contains evidence.
- Applies to impounds, contraband, or joyriding cases.
- Inventory searches before towing are lawful for documentation.
- If obtaining a house warrant, vehicles on-site must be specifically listed to be searched.