United States v. Robinson case brief

United States v. Robinson case brief summary
414 U.S. 218 (1973)

CASE SYNOPSIS

The United States sought review of the judgment from the United States Court of Appeals for the District of Columbia, which reversed defendant's conviction for possession and facilitation of concealment of her*in in violation of 26 U.S.C.S. § 4704(a), and held that a search of defendant's person violated U.S. Constitutional Amendment IV.

CASE FACTS
Defendant was pulled over by a police officer. The officer had probable cause to arrest defendant for driving after his license had been revoked. The officer then searched defendant and felt an object under defendant's coat. The officer reached into the coat and pulled out a cigarette package. The officer felt there was something in the package that was not cigarettes. The officer opened the package and found what was later determined to be her*in.

DISCUSSION

• The Court reversed the appellate court's decision and found the search permissible under U.S. Constitutional Amendment IV. 
• A search incident to a lawful arrest was clearly authorized. 
• The appellate court's decision was incorrect in that it concluded that even with probable cause for an arrest, an officer was only allowed to conduct a protective frisk for weapons. 
• When an officer had probable cause for an arrest, as the officer in the present case did, a more extensive exploration of the suspect's person was authorized. 
• This was to protect the officer, but also to preserve evidence. 
• The fact that defendant was to be arrested for a driving offense did not lessen the officer's right to search defendant.

CONCLUSION
The Court reversed the appellate court's decision, finding a police officer was clearly authorized to reach into defendant's coat as part of his search because the officer had probable cause to arrest defendant. Once probable cause to arrest defendant was established, a full search incident to that arrest was authorized in order to protect the officer's safety and to preserve evidence.



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