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Carroll v. United States Case Summary

Mar 31, 2025

Carroll v. United States, 1925

Background

  • Date: 1921
  • Individuals Involved: George Carroll and John Cairo
  • Location: Driving from Detroit to Grand Rapids, Michigan
  • Action Taken: Federal prohibition officers were following Carroll and Cairo.
  • Search Conducted: Officers pulled over their car and searched it without a warrant.
  • Findings: 69 quarts of alcohol were discovered hidden in the upholstery.

Legal Proceedings

  • Argument by Carroll:
    • Claimed that evidence should be suppressed because the search was conducted without a warrant.
  • Counterargument by Officers:
    • Claimed they were allowed to conduct warrantless searches of vehicles if they had probable cause to believe alcohol was being transported.

Supreme Court Decision

  • Decision: 7-2 ruling
  • Ruling: A warrantless search of an automobile is permissible under the Fourth Amendment.
  • Reasoning:
    • Cars are mobile, making it impracticable to obtain a warrant if there is probable cause.
    • This decision led to the establishment of the "Carroll Doctrine."

Significance

  • Established the precedent for warrantless searches of vehicles by law enforcement given probable cause, due to the inherent mobility of automobiles.