Rakas v. Illinois

Facts

A police officer on routine patrol received a radio call about a robbery of a clothing store in Bourbonnais, Ill. The call described the getaway car. Soon afterward the officer saw a car he thought might be the getaway car. He followed it, and after help arrived he and several other officers stopped it. The occupants were the petitioners and two female companions. The police ordered everyone out of the car, and two officers then searched the interior. They found a box of rifle shells in the locked glove compartment and a sawed-off rifle under the front passenger seat. The officers then took the petitioners to the station and arrested them. The petitioners were passengers, and the owner of the car had been driving it. They did not own the car, and they never claimed to own the rifle or the shells. Before trial they moved to suppress (to bar the use of) the rifle and shells, arguing that the search violated the Fourth and Fourteenth Amendments. The prosecutor argued that the petitioners lacked standing, meaning the right to object, because neither the car, the shells nor the rifle belonged to them. At trial the prosecution offered the rifle and shells into evidence on the armed robbery charge.

Issues

1. Should the Court broaden the rule of standing so that any defendant at whom a search was directed, the so-called target, can challenge the search and seek suppression of the evidence?
2. Is the question whether a defendant may challenge a search better treated as a separate matter of standing, or as part of the substantive Fourth Amendment question whether his own rights were infringed?
3. Did passengers who claimed no property or possessory interest in the car or the seized items have a legitimate expectation of privacy in its glove compartment and the area under the seat?

Holding

The petitioners were passengers who claimed no property or possessory interest in the car or the items seized and showed no legitimate expectation of privacy in the glove compartment or under the seat. The search therefore violated none of their Fourth Amendment rights, and they could not have the evidence suppressed.