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LEGAL

RESEARCH

Illinois v. Lafayette

Facts

The defendant was arrested for disturbing the peace and taken to the police station. Without obtaining a warrant and in the process of booking him and inventorying his possessions, the officers removed the contents of his shoulder bag. They found amphetamine pills.

Issue

Whether it is reasonable for the government to inventory the personal effects of a person under lawful arrest as part of the procedure at a police station?

Held

Yes. Consistent with the Fourth Amendment, it is reasonable for the government to search the personal effects of a person under lawful arrest as part of the routine administrative procedure at a police station incident to booking and jailing the suspect.

Discussion

In determining whether an inventory search is reasonable under the Fourth Amendment, government interests are balanced against the intrusion on an individual’s Fourth Amendment interests. The government has a legitimate interest in protecting the owner’s property from theft or false claims of theft by persons employed in police activities. A standardized procedure for making an inventory as soon as is reasonable after reaching the station house protects the owner’s property while it is in police custody. The fact that the protection of an arrestee’s property might have been achieved by less intrusive means does not, in itself, render an inventory search unreasonable.

Citation

462 U.S. 640, 103 S. Ct. 2605 (1983)

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