California v. Acevedo

Facts

On October 28, 1987, Officer Coleman of the Santa Ana police got a call from a federal drug agent in Hawaii. The agent had seized a package of marijuana addressed to J. R. Daza in Santa Ana and arranged to send it to Coleman. Coleman was to take it to the Federal Express office and arrest the person who came to claim it. On October 30, a man who identified himself as Jamie Daza claimed the package and carried it into his apartment. Officers later saw Daza drop the box and paper that had held the marijuana into a trash bin. About 12:05 p.m., they stopped Richard St. George as he drove off with a blue knapsack and found marijuana in it. At 12:30 p.m., Acevedo arrived, entered the apartment, and stayed about 10 minutes. He came out carrying a brown paper bag that looked full and was the size of one of the wrapped marijuana packages sent from Hawaii. He put the bag in the trunk of a silver Honda and started to drive away. Fearing the loss of evidence, officers in a marked police car stopped him, opened the trunk and the bag, and found marijuana.

Issues

1. Does the Fourth Amendment require police to get a warrant before opening a closed container in a car's trunk when they have probable cause to search only the container and not the whole car?
2. Should the rule of Chadwick and Arkansas v. Sanders, which required a warrant to search a container in that situation, be kept alongside the rule of Ross?

Holding

Police who have probable cause to believe a closed paper bag in a car's trunk holds contraband may search the bag without a warrant, even though they lack probable cause to search the rest of the car. The Court eliminated the warrant requirement for closed containers set forth in Sanders.