User:Paris1127/Illinois v. Lafayette

Illinois v. Lafayette, 462 U.S. 640 (1983), was a United States Supreme Court case in which the Court held that the police search of a suspect's shoulder bag during a routine booking was a valid inventory search and not unconstitutional.

Background
In Kankakee, Illinois, approximately 50 mi south of Chicago, police responded to a disturbance at a movie theater on the evening of September 1, 1980. Inside, Officer Maurice Mietzner found Ralph Lafayette in a fight with the manager of the theater. Lafayette was arrested and taken to the police station. During booking, Officer Mietzner asked Lafayette to remove all items from his pockets and to place them on a counter in front of him. Lafayette then opened a shoulder bag he was carrying, removed a package of cigarettes from inside, and placed the cigarettes with his pocket contents. Mietzner took the bag and removed its contents, in the process finding 10 amphetamine pills in a plastic wrapping from a pack of cigarettes. For possessing these pills, Lafayette was charged with violating the Illinois Controlled Substances Act. At a pre-trial hearing, Lafayette's lawyer attempted to suppress the pills as the product of an illegal search, while prosecutors argued it was a valid inventory search per South Dakota v. Opperman. Mietzner testified that standard procedure required him to inventory an arrested person's belongings, and that he had not expected to find drugs when he did so in this case. Later, the prosecution submitted a brief arguing that the search was valid as "a delayed search incident to arrest." The trial court ruled the pills inadmissable as the product of an illegal search. On appeal, the Illinois Appellate Court affirmed the trial court's opinion, noting that the state should have argued the validity of the search at the suppression hearing and not in a later brief. Moreover, unlike the Opperman case, where a police officer searched a vehicle, a shoulder bag demands greater privacy rights. The Supreme Court of Illinois refused to consider the case. The United States Supreme Court granted certiorari, as this question frequently confronted the police and the courts.

Opinion of the Court
In a unanimous decision, the Supreme Court reversed the Appellate Court and found for Illinois. Chief Justice Warren E. Burger wrote: "Consistent with the Fourth Amendment, it is reasonable for police to search the personal effects of a person under lawful arrest as part of the routine administrative procedure at a police station incident to booking and jailing the suspect. The justification for such searches does not rest on probable cause, and hence the absence of a warrant is immaterial to the reasonableness of the search. Here, every consideration of orderly police administration - protection of a suspect's property, deterrence of false claims of theft against the police, security, and identification of the suspect - benefiting both the police and the public points toward the appropriateness of the examination of respondent's shoulder bag."

Burger added that, even if a less-intrusive means to search a suspect existed, "it would be unreasonable to expect police officers in the everyday course of business to make fine and subtle distinctions in deciding which containers or items may be searched, and which must be sealed without examination as a unit."

Justice Thurgood Marshall, in a concurrence joined by Justice William J. Brennan, Jr., speculated that, had Illinois used solely the fact that Lafayette had been arrested as justification for a search, a warrantless search may only have been permitted to search for weapons or prevent the defendant from destroying evidence. As Mietzner did not search the bag upon the arrest of Lafayette, this was not the case. The future search of the bag would not have been considered justified in this scenario.