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Pennsylvania v. Labron


Officers observed the defendant engage in a drug transaction. They pulled him over, arrested him, searched his car and found cocaine in the trunk. The Supreme Court of Pennsylvania suppressed the cocaine because the officers could have obtained a search warrant before they searched the defendant’s car under the Carroll doctrine.


Whether the officers need to establish exigent circumstances before searching a car under the mobile conveyance exception to the Fourth Amendment’s warrant requirement?


No. Once the officers establish probable cause to search a car under the mobile conveyance exception, they do not need to obtain a warrant.


The Supreme Court established the mobile conveyance exception to the warrant requirement of the Fourth Amendment because of the necessity of coping with rapidly disappearing objects. However, the Court has shifted the focus of this exception from the exigency of the speed of the vehicle to the fact that persons have only a reduced expectation of privacy in an automobile. The Court discarded the original requirement that the government establish that the automobile searched was in immediate danger of disappearing. The Court stated “if a car is readily mobile and probable cause exists to believe it contains contraband, the Fourth Amendment thus permits police to search the vehicle without more.”


518 U.S. 938, 116 S. Ct. 2485 (1996)

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