Carroll v. United States, 267 U.S. 132 (1925), was a decision by the United States Supreme Court which upheld that the warrantless search of an automobile is known as the automobile exception. The case has also been used to increase the scope of warrantless searches.

Background

Federal prohibition officers arranged an undercover buy of liquor from George Carroll, an illicit dealer under investigation, but the transaction was not completed. They later saw Carroll and one Kiro driving on the highway from Detroit to Grand Rapids, which they regularly patrolled. They gave chase, pulled them over, and searched the car, finding illegal liquor behind the rear seat.

The National Prohibition Act provided that officers could make warrantless searches of vehicles, boats, or airplanes when they had reason to believe illegal liquor was being transported.

Opinion of the court

The Court noted that Congress early obviated the need for a warrant in border search situations, and Congress always recognized a necessary difference between searches of buildings and vehicles for contraband goods, where it is not practical to secure a warrant, because the vehicle can be quickly moved out of the locality or jurisdiction in which the warrant must be sought. The warrantless search under these circumstances was thus valid.

The Court held, however, that

[i]t would be intolerable and unreasonable if a prohibition agent were authorized to stop every automobile on the chance of finding liquor, and thus subject all persons lawfully using the highways to the inconvenience and indignity of such a search... . [T]hose lawfully within the country, entitled to use the public highways, have a right to free passage without interruption or search unless there is known to a competent official, authorized to search, probable cause for believing that their vehicles are carrying contraband or illegal merchandise.

The Court added that where the securing of a warrant is reasonably practicable, it must be used.

This became known as the Carroll doctrine: a vehicle could be searched without a warrant if there was probable cause to believe that evidence is present in the vehicle, coupled with exigent circumstances to believe that the vehicle could be removed from the area before a warrant could be obtained.Footnote 39.

Subsequent events

In United States v. Di Re, the Court declined to extend Carroll to permit searches of passengers in a vehicle which had apparently been lawfully stopped. In Di Re there was no probable cause to believe that the passenger was holding any evidence.41

The Court relied on Carroll in Cooper v. California to observe that a search of a vehicle may be reasonable where the same search of a dwelling may not be reasonable.

Due to a recent decision rendered by the US Supreme Court in Arizona v. Gant

Arizona v. Gant

Arizona v. Gant, 556 U.S. 332 , was a United States Supreme Court decision which held that the Fourth Amendment to the United States Constitution requires law enforcement officers to demonstrate an actual and continuing threat to their safety posed by an arrestee, or a need to preserve evidence...

, there may be new restrictions on warrantless searches of automobiles under certain, limited circumstances. Arizona v. Gant does not automatically preclude Carroll v. US and does not repeal it.

See also

• List of United States Supreme Court cases, volume 267
• Boyd v. United States
  Boyd v. United States
  Boyd v. United States, , was a decision by the United States Supreme Court, which held that “a search and seizure [was] equivalent [to] a compulsory production of a man's private papers” and that the search was “an 'unreasonable search and seizure' within the meaning of the Fourth Amendment.”In the...
  
  ,
• Weeks v. United States
  Weeks v. United States
  In Weeks v. United States, 232 U.S. 383 , the United States Supreme Court unanimously held that the warrantless seizure of items from a private residence constitutes a violation of the Fourth Amendment...
  
  ,
• Chambers v. Maroney
  Chambers v. Maroney
  In Chambers v. Maroney , the United States Supreme Court applied the Carroll doctrine in a case with a significant factual difference—the search took place after the vehicle was moved to the stationhouse. The search was thus delayed and did not take place on the highway as in Carroll...
  
  ,
• United States v. Chadwick
  United States v. Chadwick
  United States v. Chadwick, 433 U.S. 1 , was a decision by the United States Supreme Court, which held that, absent exigency, the warrantless search of double-locked luggage just placed in the trunk of a parked vehicle is a violation of the Fourth Amendment and not justified under the automobile...
  
  ,