Illinois v. Lafayette case brief

Illinois v. Lafayette case brief summary
462 U.S. 640 (1983)

CASE SYNOPSIS

On certiorari, the State challenged a judgment from the Appellate Court of Illinois, Third District, which affirmed a trial court's decision granting defendant's motion to suppress narcotics that were found in his shoulder bag during a post-arrest, warrantless search at a police station.

CASE FACTS
Defendant was arrested for disturbing the peace. When he arrived at the police station, he removed cigarettes from the shoulder bag he was carrying and then placed it on the counter in the station. As part of a routine booking procedure, an officer emptied and inventoried the contents of the bag. Narcotics were found in the bag and defendant was subsequently charged with violating the state's controlled substances statute. On defendant's motion, the state trial court suppressed the drugs and that judgment was affirmed on appeal.

DISCUSSION

• On certiorari, a majority of the Court held that the search was not invalid under the Fourth Amendment. 
• Specifically, the Court held that because the search was conducted as a part of a routine administrative procedure that was incident to defendant's arrest and incarceration, the search was not unreasonable. 
• In such circumstances, the police could search any container in defendant's possession. 
• The Court reasoned that such a search was supported by the State's interest in safeguarding defendant and his property as well avoiding possible claims of theft by the police.

CONCLUSION

The Court reversed and remanded the judgment below. The warrantless search of defendant's shoulder bag, which was conducted pursuant to standard booking procedures as an inventory of defendant's belongings, was not unreasonable under the Fourth Amendment. The narcotics found in the bag were thus improperly suppressed.

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