Chambers v. Maroney

In Chambers v. Maroney, 399 U.S. 42 (1970), the Supreme Court considered "the admissibility of evidence seized from an automobile, in which petitioner was riding at the time of his arrest, after the automobile was taken to a police station and was there thoroughly searched without a warrant." Id. at 43. In that case, the Court noted that the removal of the vehicle from the scene of arrest to the station house was "not unreasonable" because "a careful search at the scene of arrest was impractical and perhaps not safe for the officers . . . ." Id. at 52 n.10. The Chambers Court held that once the police obtained probable cause and could permissibly search the vehicle under the Carroll doctrine (Carroll v. United States) at the scene of the arrest, the probable cause factor "still obtained at the station house" after the vehicle was towed, and it was constitutionally permissible to continue the search without a warrant. Id.