Erickson v. State
In Erickson v. State, 507 P.2d 508 (Alaska 1973), a police informant had seen the defendant place drugs in a suitcase. The informant recovered the suitcase from its hiding place outside and brought it to the police station. The suitcase was locked. The informant told the police that he had seen the defendant place the drugs in the suitcase, but he had not searched the suitcase before turning it over to the police. The police opened the suitcase without getting a warrant.
The Alaska Supreme Court held that the police needed a warrant to search the locked suitcase. The Erickson decision appears to be consistent with United States v. Jacobsen.
Because the informant had not previously searched the suitcase, the police substantially exceeded the earlier intrusion, i.e., the seizure of the suitcase. The defendant in Erickson retained a reasonable expectation of privacy in the contents of the suitcase. But in Erickson, the Supreme Court never addressed the issue of whether the informant's seizure of the suitcase was unlawful.