Caseflicks

Supreme Court of the United States • 1970

Chambers v. Maroney

399 U.S. 42 | 90 S. Ct. 1975 | 26 L. Ed. 2d 419 | 1970 U.S. LEXIS 19

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Takeaway

In short, this case holds that when police have probable cause to search a readily movable car, they may search it without a warrant even after taking it to the station house; the Court treated that search as constitutionally equivalent to immediately searching or temporarily seizing the vehicle.

Background

After two armed men robbed a Gulf service station in North Braddock, Pennsylvania, witnesses reported that a light-blue compact station wagon carrying four men had fled nearby. They described one man as wearing a green sweater; the victim also described the robbers as wearing a green sweater and a trench coat. Within an hour, police stopped a matching station wagon about two miles away. Chambers was one of its four occupants, wore a green sweater, and a trench coat was in the car.

Police arrested all four men and took the station wagon to the police station. During a thorough warrantless search there, officers found two .38-caliber revolvers, a glove containing coins, and cards belonging to the victim of an earlier service-station robbery. The day after the arrest, police conducted a warrant-authorized search of Chambers's home and seized .38-caliber ammunition. Chambers was convicted of both robberies after his first trial ended in a mistrial.

Chambers later pursued state and then federal habeas relief, challenging the vehicle search, the admission of the ammunition found at his home, and the effectiveness of counsel at his second trial. The federal district court denied relief without an evidentiary hearing, and the Third Circuit affirmed. The Supreme Court granted certiorari and affirmed.

Issues

Issue #1

Whether the police had probable cause to arrest the occupants of the station wagon.

Holding

Yes. The officers had probable cause to stop the vehicle and arrest its occupants.

Reasoning

The police had promptly received converging descriptions from eyewitnesses and the robbery victim: a light-blue compact station wagon with four men had left the vicinity, one man wore a green sweater, and another robber wore a trench coat. The stopped vehicle matched the description, was found only two miles away within an hour, and contained four men, including Chambers in a green sweater and a trench coat in the car.

reasoning

Issue #2

Whether police could conduct a warrantless search of the station wagon at the police station after arresting its occupants and taking the car into custody.

Holding

Yes. Because officers had probable cause to believe the vehicle contained the guns and proceeds of the robberies, the warrantless station-house search was reasonable under the automobile exception.

Reasoning

The search could not be justified as incident to arrest. Under Preston v. United States, once an arrestee is securely in custody and the search occurs later at another location, the usual justifications for a search incident to arrest no longer apply.

reasoning

Issue #3

Whether the admission of .38-caliber ammunition seized from Chambers's home required reversal.

Holding

No. Even if admitting the ammunition was error, the error was harmless beyond a reasonable doubt.

Reasoning

The record concerning the warrant, probable cause, and state suppression procedures was unclear. But both lower federal courts concluded that any error in admitting the ammunition was harmless, and the Supreme Court found no basis to reject that conclusion after reviewing the record.

reasoning

Issue #4

Whether the late substitution of counsel before Chambers's second trial required an evidentiary hearing or reversal for ineffective assistance of counsel.

Holding

No. On this record, the lower courts could reject the claim without an evidentiary hearing.

Reasoning

Chambers met his second-trial lawyer only shortly before trial, but he did not claim that the lawyer was incompetent or inexperienced. His claimed prejudice focused chiefly on counsel's alleged failure to exclude the guns and ammunition.

reasoning

Concurrences

Justice Stewart

Reasoning

Justice Stewart joined the Court's opinion and judgment because existing doctrine required consideration of Chambers's Fourth and Fourteenth Amendment claims on habeas review. He reiterated, however, his separate view that the admission at trial of evidence allegedly obtained in violation of the Fourth Amendment should not itself provide a basis for collateral attack on an otherwise valid criminal conviction.

Dissents

Justice Harlan

Reasoning

Justice Harlan agreed that admission of the ammunition from Chambers's home, considered by itself, was harmless. But he would not have affirmed the judgment because he believed Chambers made a sufficient showing to require an evidentiary hearing on whether his trial lawyer's last-minute appointment deprived him of genuinely effective assistance.

reasoning