Carroll v. United States

Carroll v. United States

Supreme Court of the United States

45 S.Ct. 280 (1925)

Facts of the Case

On September 29, 1921, government agents Cronenwett and Scully attempted to purchase liquor from the two defendants, Carroll and Kiro, and a third party. However, the transaction between the men was never completed. Several months later on December 15, 1921, the agents recognized defendants driving a motor vehicle and followed the car. Agents pulled the car over and searched the vehicle, without a warrant, discovering alcohol hidden behind the seats. Defendants were indicted and convicted for transporting alcohol in an automobile and for violation of the National Prohibition Act.

Basis of Appeal

On appeal, Carroll claimed that the lower court erred by allowing the admission of the alcohol, citing that the search of the vehicle without a warrant was in violation of the Fourth Amendment as was the violation in the United States versus Metter.

Disposition

In Carroll, the Supreme Court ruled that probable cause existed for the agent’s search in that there was a reasonable belief that the automobile contained evidence of a crime. According to the court, fixed dwellings are afforded a different level of protection from unreasonable search and seizure, because vehicles may be moved out of the jurisdiction before a warrant may be obtained. This makes the requirement of a warrant impractical. The Supreme Court, therefore, utilized sufficient federal oversight and affirmed the lower court’s conviction of Carroll, ruling that the agents had probable cause to search Carroll’s vehicle without a warrant.