This directly overturned the ruling in Wolf v. Colorado, which stated explicitly that the Fourteenth Amendment did not disallow illegally obtained evidence from being used in a state trial.
United States v. Robinson
414 U.S. 218 (1973)
Facts: Mr. Robinson was arrested for driving without a license by an officer who was made previously aware of the fact that Mr. Robinson's license had been suspended. During the post-arrest search, a packet of heroin was found on Mr. Robinson's person; he was convicted of possession.
Issue: Was there enough probable cause for the search, or was it unwarranted and therefore unreasonable?
Holding: The search was deemed valid and the conviction upheld.
Reasoning: As the search was conducted as part of standard police procedure following an arrest, especially for observed criminal activity, the issue of probable cause did not apply to the search's reasonability. The search was not abusive or extreme, and extended only to the defendant's person, and was therefore within the scope of vested police authority.
Florida v. Wells
495 U.S. 1 (1990)
Facts: Mr. Wells was arrested for driving while intoxicated, and consented to the opening of the trunk of his car while it was being impounded. In addition to two consent to open the trunk of the car, did Florida State Highway patrol have enough probable cause to force open any container found therein?
Holding: The search was deemed unconstitutional and the conviction overturned.
Reasoning: No probable cause was found to exist, and as there was no precedent for such a search by Florida authorities existed the search was deemed invalid, though the court allowed for the establishment of procedural rules by law enforcement agencies that could make a similar search legal in future cases, with some dissent on this issue.
References
Cornell University Law School. (2009). "Amendment IV." The U.S. Constitution. Accessed 5 October 2009. http://www.law.cornell.edu/anncon/html/amdt4frag1_user.html#amdt4_hd4
Franklin, P. (1991). The Fourth Amendment. New York: Silver Burdett Press.
Justia. (2009). U.S. Supreme Court Center. Accessed 5 October 2009.
http://supreme.justia.com/index.html
