In Chambers v. Maroney , the United States Supreme Court applied the Carroll doctrine

Carroll v. United States

Carroll v. United States, 267 U.S. 132 , was a decision by the United States Supreme Court which upheld that the warrantless search of an automobile is known as the automobile exception...

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 (or street) as in Carroll. After a gas station robbery, a vehicle fitting the description of the robbers' car was stopped. Inside were people wearing clothing matching the description of that worn by the robbers. They were arrested, and the car was taken to the police station where it was later searched.

Opinion of the Court

The Court first held that the search could not be sustained as a search incident under Preston and Dyke. It quoted at length from Carroll that a search of a movable vehicle is treated differently under the Fourth Amendment because the mobility of the vehicle alone can easily defeat the warrant requirement. If there is probable cause to believe the vehicle contains criminal evidence and there exist exigent circumstances where the vehicle can be removed from the jurisdiction, a warrantless search would be reasonable. It made no constitutional difference here that the search followed the seizure because the probable cause which developed on the street still existed at the stationhouse. For this purpose, it is significant to note that the automobile exception and the search incident doctrine are quite different.

Further reading

Chambers is discussed in:

• Note, 75 Dick L Rev 511 (1971);
• Note, 46 Ind L J 257 (1971);
• Comment, 47 Notre Dame Law 668 (1972);
• Note, 7 Tulsa L J 197 (1971);
• Note, 23 Vand L Rev 1370 (1970).
• Heisse, Warrant1ess Automobile Searches and Telephonic Search Warrants: Should the Automobile Exception be Redrawn?, 7 Hast Const L Q 1031 (1980).