Sunday, November 17, 2013

United States v. Hartwell case brief

United States v. Hartwell case brief summary
436 F.3d 174 (2006)

Defendant sought review of a judgment from the United States District Court for the Eastern District of Pennsylvania, which held that an airport search of defendant that resulted in the confiscation of crack cocaine from his pocket did not offend the Fourth Amendment.

Defendant set off a metal detector at a security checkpoint in an airport. Transportation Security Administration agents then used a magnetic wand to pinpoint any metal on his person. They detected something in defendant's pocket and asked to see it. Ultimately, they discovered that the object was crack cocaine and placed defendant under arrest. Defendant argued that the drugs should have been suppressed because the search offended the Fourth Amendment.

The district court held that it did not, and the court on appeal affirmed.


  • According to the court, the search was permissible under the administrative search doctrine. 
  • Applying the Brown v. Texas balancing test, the court noted that there could be no doubt that preventing terrorist attacks on airplanes was of paramount public importance and that airport checkpoints have been an effective, yet minimally intrusive way to preserve air travel safety. 
  • Therefore, the search in this case was permissible under the administrative search doctrine because the State had an overwhelming interest in preserving air travel safety, and the procedure was tailored to advance that interest while proving to be only minimally invasive.

The court affirmed the judgment.

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