Illinois v. Rodriguez case brief summary
497 U.S. 177 (1990)
Defendant was charged with possession of a controlled substance with intent to deliver. Defendant's motion to suppress evidence seized at the time of his arrest was granted by the state trial court. The Appellate Court of Illinois affirmed the trial court's decision. The Illinois Supreme Court denied the State's petition for leave to appeal. The State sought review, and the Court granted certiorari.
CASE FACTS
The State argued that defendant's former roommate still retained control over defendant's apartment and, therefore, had common authority over the premises to consent to the police search. The State also argued that even if the roommate lacked control or authority, the search and seizure was still proper under the Fourth Amendment because the police reasonably believed that she had authority to consent. Defendant asserted that permitting a reasonable belief of common authority would cause his Fourth Amendment rights to be "vicariously waived."
DISCUSSION
The Court held that "common authority" rested on mutual use of the property and that there was sufficient proof in the record that the State failed to satisfy its burden that defendant's former roommate had joint access or control over the apartment. The officers' reasonable belief that the roommate had common authority over the apartment could have validated the search, but the lower courts failed to render a decision on the issue.
CONCLUSION
The judgment was reversed and the case remanded for further determination whether the police officers possessed a reasonable belief that defendant's former roommate had common authority over the apartment.
Recommended Supplements for Criminal Procedure Criminal Procedure: Examples & Explanations, Sixth Edition
Emanuel Law Outline: Criminal Procedure
497 U.S. 177 (1990)
Defendant was charged with possession of a controlled substance with intent to deliver. Defendant's motion to suppress evidence seized at the time of his arrest was granted by the state trial court. The Appellate Court of Illinois affirmed the trial court's decision. The Illinois Supreme Court denied the State's petition for leave to appeal. The State sought review, and the Court granted certiorari.
CASE FACTS
The State argued that defendant's former roommate still retained control over defendant's apartment and, therefore, had common authority over the premises to consent to the police search. The State also argued that even if the roommate lacked control or authority, the search and seizure was still proper under the Fourth Amendment because the police reasonably believed that she had authority to consent. Defendant asserted that permitting a reasonable belief of common authority would cause his Fourth Amendment rights to be "vicariously waived."
DISCUSSION
The Court held that "common authority" rested on mutual use of the property and that there was sufficient proof in the record that the State failed to satisfy its burden that defendant's former roommate had joint access or control over the apartment. The officers' reasonable belief that the roommate had common authority over the apartment could have validated the search, but the lower courts failed to render a decision on the issue.
CONCLUSION
The judgment was reversed and the case remanded for further determination whether the police officers possessed a reasonable belief that defendant's former roommate had common authority over the apartment.
Recommended Supplements for Criminal Procedure Criminal Procedure: Examples & Explanations, Sixth Edition
Emanuel Law Outline: Criminal Procedure
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