ABSTRACT

The seminal case with regard to automobile searches is Carroll v. United States, 267 US 132, in which the US Supreme Court articulated an exception to the warrant requirement of the Fourth Amendment for automobile searches. In this Prohibition-era case, law enforcement agents stopped the car in which George Carroll and John Kiro were driving based on their belief that the two were transporting liquor in violation of the National Prohibition Act. Although people enjoy greater protections under the Fourth Amendment than automobiles, drivers are subject to search, without a search warrant, when arrested for a traffic offense, as the Court ruled in United States v. Robinson, 414 US 218. The Court has likewise enhanced the scope of law enforcement discretion to search containers in automobiles, though the line of precedent on this point has been confusing at times.