Carroll v. United States: Case Brief

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  • 0:02 Your Privacy, Your…
  • 0:48 Facts of the Case
  • 1:47 Questions Presented to…
  • 2:36 Holding of the Supreme Court
  • 2:55 Analysis of the Supreme Court
  • 4:27 Lesson Summary
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Lesson Transcript
Instructor: Brittany McKenna

Brittany is a licensed attorney who specializes in criminal law, legal writing, and appellate practice and procedure.

In the landmark Carroll v. United States case, the Supreme Court established the 'vehicle exception' to the search warrant requirement of the Fourth Amendment. Complete this lesson to learn more.

Your Privacy, Your Car, And You

Have you ever been out driving and stopped at a red light only to look over and see the person in the car next to you singing or dancing wildly -- or worse -- picking their nose? If you have, then you're definitely not alone. Across the globe, people have witnessed this particular phenomenon -- that is, the strange sense of privacy that many seem to get when behind the wheel of their car, almost as though they can't be observed.

Unfortunately, this sense of privacy is not without its limits. There are instances where public safety will take precedent over one's interest in privacy. In the famous Carroll v. United States case, the Supreme Court contemplated exactly how much right to privacy we have in our own vehicles and the limitations of those rights under the Fourth Amendment.

Facts of the Case

The year was 1921 -- the height of the Prohibition Era in the United States. The Volstead Act, which was formally known as the National Prohibition Act, criminalized the production, sale, and transportation of alcohol, and federal prohibition agents were on the lookout for illegal alcohol sellers, also known as bootleggers.

In Michigan, federal agents were mounting a case against notorious bootlegger George Carroll. The agents strongly suspected that Carroll was transporting and selling liquor, but their attempts to catch him in the act were proving unsuccessful. One night in December, the agents followed Carroll and his associate, John Kiro, as the pair drove from Detroit to Grand Rapids. The agents pulled Caroll and Kiro over on the highway and searched the vehicle.

As they searched Carroll's vehicle, agents discovered 68 bottles of illegal liquor concealed in the back seat upholstery. The agents arrested Carroll for violating the Volstead Act. Carroll appealed his conviction all the way to the Supreme Court.

Questions Presented to the Supreme Court

The Fourth Amendment of the United States Constitution, which protects an individual's right to privacy, forbids unlawful searches and seizures of homes and property. If a law enforcement officer desires to search a suspect's home, the officer must first secure a search warrant to do so.

The Volstead Act of 1919 carved out an explicit exception to the warrant requirement that allowed law enforcement officers to conduct warrantless searches of cars, boats, and airplanes if the officers believed that the vehicle in question was carrying contraband -- specifically, intoxicating liquors.

The question presented to the Supreme Court in Carroll was: does the Volstead Act's exception to the warrant requirement violate the Fourth Amendment? In other words, can law enforcement officers search a vehicle without first obtaining a warrant?

Holding of the Supreme Court

The Supreme Court ruled that law enforcement officers may conduct a warrantless search of a vehicle when the officers have probable cause to believe that evidence of a crime, or contraband, will be found as a result of the search. This rule has come to be known as the automobile exception to the warrant requirement.

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