Opinion · Supreme Court of the United States

Maryland v. Dyson

527 U.S. 465

Type
Opinion
Court
Supreme Court of the United States
Jurisdiction
Federal
Date
1999-06-21
Topic
litigation

How later courts describe this case

  • holding that probable cause supported police search of a vehicle when a "reliable confidential informant" told officers that "a rented red Toyota" with a particular license number would contain drugs
  • holding that there need not be an exigency for the automobile exception to apply
  • holding that under the "automobile execution,” a vehicle may be searched without a warrant based on probable cause alone
  • concluding that “[the finding] that the car contained contraband . . . alone satisfies the automobile exception to the Fourth 32 Amendment’s warrant requirement”
  • holding that established precedent has made clear that probable cause is threshold for satisfying automobile exception, and nothing more is required
  • recognizing that police may search a car without a warrant if there is probable cause to believe that it contains evidence of drug activity
  • holding that a “finding [of probable cause] alone satisfies the automobile exception to the Fourth Amendment’s warrant requirement”
  • holding that where probable cause for the search of an automobile exists, an officer need not show exigent circumstances beyond the inherent mobility of the vehicle in order to justify a search

Citator

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Cited by
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Headnotes

  1. Criminal Law & Procedure — Automobile Exception The automobile exception to the Fourth Amendment's warrant requirement does not require a separate finding of exigency in addition to a finding of probable cause; where there is probable cause to search a vehicle, a search is not unreasonable if based on facts that would justify the issuance of a warrant, even though a warrant has not actually been obtained. 527 U.S. 465 (citing United States v. Ross, 456 U.S. 798, 809 (1982))
  2. Criminal Law & Procedure — Automobile Exception If a car is readily mobile and probable cause exists to believe it contains contraband, the Fourth Amendment permits police to search the vehicle without more. 527 U.S. 465 (citing Pennsylvania v. Labron, 518 U.S. 938, 940 (1996) (per curiam))
  3. Criminal Law & Procedure — Automobile Exception A finding of probable cause that a vehicle contains contraband, standing alone, satisfies the automobile exception to the Fourth Amendment's warrant requirement; no additional exigency precluding the police from obtaining a warrant need be shown. 527 U.S. 465
  4. Federal Courts & Jurisdiction — Summary Reversal A summary reversal does not decide any new or unanswered question of law, but simply corrects a lower court's demonstrably erroneous application of federal law; the Court need not appoint an amicus curiae to brief a criminal case before summarily reversing where the respondent's counsel is unable to file a response. 527 U.S. 465 n.*
MARYLAND v. DYSON,527 U.S. 465(1999)
MARYLANDv. KEVIN DARNELL DYSON
ON PETITION FOR WRIT OF CERTIORARI TO THE COURT OF SPECIAL APPEALS OF
MARYLAND
No. 98-1062
Decided June 21, 1999
After receiving a tip from a reliable infomant, sheriffs deputies stopped and searched respondet's vehicle and found 23 grams of cocaine in the trunk. The Court of Special Appeals reversed his drug conviction, holdign that in order for the automobile exception to theFourth Amendment'swarrant requirement to apply there must not only be probable cause to believe that evidence of a crime is contained in the car, but also a separate finding of exigency precluding the police from obtaining a warrant.Held:The automabile exceptiondoes not require a separate finding of exigency in addition to a finding of probale acause. This Court's established precedent makes clear that in cases where there was probable cause to search a vehicle, a search is not unreasonable if based on facts that would justify issuing a warrant, even though a warrant has not been actually abtained.E.g., United Statesv.Ross,456 U.S. 798,809. Here, the lower court found "abundant probable cause" that the car contained contraband, which alone satisfies the warrant requirement's automobile exception.

Certiorari granted;122 Md. App. 413.712 A.2d 573, reversed.
PER CURIAM.
In this case, the Maryland Court of Special Appeals held that theFourth Amendmentrequires police to obtain a search warrant before searching a vehicle which they have probable cause to believe contains illegal drugs. Because this holding rests upon an incorrect interpretation of the automobile exception to theFourth Amendment'swarrant requirement, we grant the petition for certiorari and reverse.

At 11 a.m. on the morning of July 2, 1996, a St. Mary's County (Maryland) Sheriff's Deputy received a tip from a reliable confidential informant that respondent had gone to New York to buy drugs, and would be returning to Maryland in a rented red Toyota, license number DDY 787, later that day with a large quantity of cocaine. The deputy investigatedPage 466the tip and found that the license number given to him by the informant belonged to a red Toyota Corolla that had been rented to respondent, who was a known drug dealer in St. Mary's County. When respondent returned to St. Mary's County in the rented car at 1 a.m. on July 3, the deputies stopped and searched the vehicle, finding 23 grams of crack cocaine in a duffel bag in the trunk. Respondent was arrested, tried, and convicted of conspiracy to possess cocaine with intent to distribute. He appealed, arguing that the trial court had erroneously denied his motion to suppress the cocaine on the alternative grounds that the police lacked probable cause, or that even if there was probable cause, the warrantless search violated theFourth Amendmentbecause there was sufficient time after the informant's tip to obtain a warrant.

The Maryland Court of Special Appeals reversed,122 Md. App. 413,712 A.2d 573(1998), holding that in order for the automobile exception to the warrant requirement to apply, there must not only be probable cause to believe that evidence of a crime is contained in the automobile, but also a separate finding of exigency precluding the police from obtaining a warrant.Id., at 424,712 A.2d, at 578. Applying this rule to the facts of the case, the Court of Special Appeals concluded that although there was "abundant probable cause," the search violated theFourth Amendmentbecause there was no exigency that prevented or even made it significantly difficult for the police to obtain a search warrant.Id., at 426,712 A.2d, at 579. The Maryland Court of Appeals denied certiorari.351 Md. 287,718 A.2d 235(1998). We grant certiorari and now reverse.

TheFourth Amendmentgenerally requires police to secure a warrant before conducting a search.Californiav.Carney,471 U.S. 386,390-391(1985). As we recognized nearly 75 years ago inCarrollv.United States,267 U.S. 132,153(1925), there is an exception to this requirement for searches of vehicles. And under our established precedent, the "automobile exception" has no separate exigency requirement.Page 467We made this clear inUnited Statesv.Ross,456 U.S. 798,809(1982), when we said that in cases where there was probable cause to search a vehicle "a search is not unreasonable if based on facts that would justify the issuance of a warrant,even though a warrant has not beenactually obtained." (Emphasis added.) In a case with virtually identical facts to this one (even down to the bag of cocaine in the trunk of the car),Pennsylvaniav.Labron,518 U.S. 938(1996)(per curiam), we repeated that the automobile exception does not have a separate exigency requirement: "If a car is readily mobile and probable cause exists to believe it contains contraband, theFourth Amendment. . . permits police to search the vehicle without more."Id., at 940.

In this case, the Court of Special Appeals found that there was "abundant probable cause" that the car contained contraband. This finding alone satisfies the automobile exception to theFourth Amendment'swarrant requirement, a conclusion correctly reached by the trial court when it denied respondent's motion to suppress. The holding of the Court of Special Appeals that the "automobile exception" requires a separate finding of exigency in addition to a finding of probable cause is squarely contrary to our holdings inRossandLabron. We therefore grant the petition for writ of certiorari and reverse the judgment of the Court of Special Appeals.fn*It is so ordered.Page 468
JUSTICE BREYER, with whom JUSTICE STEVENS joins, dissenting.
I agree that the Court'sper curiamopinion correctly states the law, but because respondent's counsel is not a member of this Court's bar and did not wish to become one, respondent has not filed a brief in opposition to the petition for certiorari. I believe we should not summarily reverse in a criminal case, irrespective of the merits, where the respondent is represented by a counsel unable to file a response, without first inviting an attorney to file a brief asamicus curiaein response to the petition for certiorari. For this reason, I dissent.Page 469
  1. JUSTICE BREYER in dissent suggests that we should not summarily reverse a judgment in a criminal case, even though he agrees with this opinion as a matter of law. But to adopt that position would simply leave it in the hands of a respondent — who had obtained a lower court judgment manifestly wrong as a matter of federal constitutional law — to avoid summary reversal by the simple expedient of refusing to file a response. While we have on occasion appointed an attorney to file a brief asamicuscuriaein a case where we havegrantedcertiorari, in order to be sure that the argued case is fully briefed, we have never done so in cases which we have summarily reversed. The reason for this is that a summary reversal does not decide any new or unanswered question of law, but simply corrects a lower court's demonstrably erroneous application of federal law. ↩