Carroll v. United States

In Carroll v. United States, 267 U.S. 132 (1925), the Supreme Court established what would later be commonly referred to as the automobile exception to the warrant requirement. There, the defendants challenged their convictions of "transporting in an automobile intoxicating spirituous liquor . . . in violation of the National Prohibition Act." Id. at 134. The contraband was discovered when federal and state agents stopped the defendants' car and recovered numerous bottles of liquor during a vehicle search. On appeal, the defendants argued that the search and seizure violated the Fourth Amendment. The Court rejected that argument, stating: The true rule is that if the search and seizure without a warrant are made upon probable cause, that is, upon a belief, reasonably arising out of circumstances known to the seizing officer, that an automobile or other vehicle contains that which by law is subject to seizure and destruction, the search and seizure are valid. The Fourth Amendment is to be construed in the light of what was deemed an unreasonable search and seizure when it was adopted, and in a manner which will conserve public interests as well as the interests and rights of individual citizens. Id. at 149. The Carroll Court's conclusion was premised, at least in part, on the following reasoning: The guaranty of freedom from unreasonable searches and seizures by the Fourth Amendment has been construed, practically since the beginning of the Government, as recognizing a necessary difference between a search of a store, dwelling house or other structure in respect of which a proper official warrant readily may be obtained, and a search of a ship, motor boat, wagon or automobile, for contraband goods, where it is not practicable to secure a warrant because the vehicle can be quickly moved out of the locality or jurisdiction in which the warrant must be sought. Id. at 153.