Monday, December 23, 2013

Maryland v. Dyson case brief

Maryland v. Dyson case brief summary
527 U.S. 465 (1999)

CASE SYNOPSIS
Petitioner, the state of Maryland, petitioned for writ of certiorari for review of a judgment of the Court of Special Appeals of Maryland, which held that U.S. Constitutional Amendment IV required police to obtain a search warrant before searching a vehicle that they had probable cause to believe contained illegal drugs.

CASE FACTS
A sheriff's deputy received a tip from a reliable, confidential informant that respondent had gone to buy drugs and would be returning in a certain car with a specific license number. Respondent was stopped; deputies searched the car, and they found a large amount of c*caine in a duffel bag in the trunk. The state court of special appeals reversed respondent's conviction for conspiracy to possess c*caine with intent to distribute because it held that U.S. Constitutional Amendment IV, required police to obtain a search warrant before searching a vehicle that they had probable cause to believe contained illegal drugs. The Court granted certiorari to petitioner, the state of Maryland, and reversed.

DISCUSSION

  • The Court ruled that although U.S. Constitutional Amendment IV generally required police to secure a warrant before conducting a search, there was an exception for searches of vehicles. 
  • The automobile exception to the warrant requirement did not have a separate exigency requirement. 
  • The Court said that if a car was readily mobile and probable cause existed to believe it contained contraband, U.S. Constitutional Amendment IV permitted police to search the vehicle without more.

CONCLUSION
The Court granted the petition of certiorari and reversed because the state court's holding rested upon an incorrect interpretation of the automobile exception to theU.S. Constitutional Amendment IV's warrant requirement.

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