Caseflicks

Supreme Court of the United States • 1964

Preston v. United States

376 U.S. 364 | 84 S. Ct. 881 | 11 L. Ed. 2d 777 | 1964 U.S. LEXIS 1578

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Takeaway

In short, this case holds that an arrest does not authorize police to postpone a vehicle search until the arrestees and car are securely separated; absent another exception, officers must obtain a warrant.

Background

At 3 a.m., Newport, Kentucky, police responded to a report that three suspicious men had been sitting in a car parked in a business district since the prior evening. The men, including Preston, gave officers evasive answers about why they were there, said they were unemployed, collectively possessed only 25 cents, and could not substantiate their account that they were waiting for a truck driver. One man said he had purchased the car the previous day but could not produce title papers.

The officers arrested the men for vagrancy, frisked them, and took them to the police station. An officer drove the car to the station, and it was then towed to a garage. After the men had been booked and were in custody, officers searched the car at the garage without a warrant. They found loaded revolvers in the glove compartment and, after returning later to gain access to the trunk through the back seat, found items suggesting a planned bank robbery, including masks, rope, pillow slips, and a false license plate. A companion later confessed to a planned bank robbery, and the police gave the seized items to the FBI.

Preston and others were convicted in federal district court of conspiring to rob a federally insured bank. The Court of Appeals for the Sixth Circuit affirmed, rejecting their Fourth Amendment objections to both the vagrancy arrests and the vehicle search. The Supreme Court granted certiorari and reversed.

Issues

Issue #1

Whether the warrantless search of Preston's car at a garage, after the occupants had been arrested and taken to the police station, was valid as a search incident to arrest.

Holding

No. The search was too remote in time and place from the arrests to qualify as a valid search incident to arrest.

Reasoning

The Fourth Amendment generally requires a warrant before officers search, subject to carefully defined exceptions. A lawful arrest permits a contemporaneous warrantless search of the arrestee and items within the arrestee's immediate control. That limited authority protects officers from weapons, prevents escape, and preserves evidence that could otherwise be destroyed.

Those justifications did not exist when police searched Preston's car. Preston and his companions had already been arrested, booked, and held at the police station, while the car was securely in police custody at a garage. The men could no longer reach weapons or evidence in the vehicle, destroy its contents, or drive it away.

Even assuming that the initial arrests were valid, or that police had probable cause to believe the car was stolen and therefore could have searched it when they first encountered it, that assumption did not validate the later garage search. The reasonableness of a search must be assessed at the time and place it occurs. Because this search was separated from the arrest in both time and location, officers needed a warrant before conducting it.

Issue #2

Whether the Court needed to decide the validity of the vagrancy arrests to resolve the Fourth Amendment challenge.

Holding

No. The Court assumed, without deciding, that the arrests were valid because the later vehicle search was unconstitutional even on that assumption.

Reasoning

The Court did not resolve whether the vagrancy arrests themselves complied with the Fourth Amendment. Instead, it accepted the Government's most favorable premise—that the arrests were lawful, or that police otherwise had grounds to search the car at the scene—and held that the subsequent warrantless search still could not be justified as incident to arrest.

This approach made the dispositive point clear: a valid arrest does not create an open-ended authority to conduct delayed searches of property that is no longer within an arrestee's control. Since the unconstitutional garage search supplied the evidence used against Preston, the evidence was inadmissible and the conviction could not stand.