NCJ Number
97544
Date Published
1983
Length
0 pages
Annotation
This police training video cassettes, accompanied by an audio cassette, reenacts the incident that led to the U.S. Supreme Court decision in U.S. v. Robinson (1973) and highlights principles of that decision, which stated that police officers can conduct a full body search of a person under lawful custodial arrest, even if that arrest is for a traffic violation.
Abstract
A police officer stopped Willie Robinson, who was driving with a revoked driver's license in the District of Columbia, and arrested him for driving with the revoked license. Before transporting him to police headquarters, the officer conducted a full body search of Robinson and found a crumpled cigarette package inside a coat pocket. Heroin capsules were found inside the package. The officer testified that he did not suspect the motorist was armed, nor was he specifically looking for any evidence. The trial court upheld the search, and the evidence was used to convict Robinson of heroin possession. The court of appeals reversed the trial court's decision and held that the officer violated the motorist's fourth amendment rights when he searched the motorist's coat pocket. The Supreme Court reversed this decision and held that the officer had a right to make the search and that the evidence was properly seized. It found that a custodial arrest of a suspect based on probable cause is a reasonable intrusion under the fourth amendment and, with the intrusion being lawful, a search incident to the arrest requires no additional justification. In New York v. Belton (1981), the Supreme Court has extended the Robinson rule to include the passenger compartment of an Robinson rule to include the passenger compartment of an automobile. Accompanying the video is a booklet that summarizes the incident and the case's progress through the courts and that explains the rationale for the Supreme Court's decision.