Arkansas v. Sanders, 442 U.S. 753 (1979), was a decision by the United States Supreme Court, which held that absent exigency, the warrantless search of personal luggage merely because it was located in an automobile lawfully stopped by the police, is a violation of the Fourth Amendment and not justified under the automobile exception. Similar to United States v. Chadwick (1977), the luggage was the subject of police suspicion before being placed in the vehicle.

Arkansas v. Sanders
Argued February 27, 1979
Decided June 20, 1979
Full case nameArkansas v. Sanders
Citations442 U.S. 753 (more)
99 S. Ct. 2586; 61 L. Ed. 2d 235
Case history
PriorSanders v. State, 262 Ark. 595, 559 S.W.2d 704 (1977); cert. granted, 439 U.S. 891 (1978).
Holding
Absent exigency, the warrantless search of personal luggage merely because it was located in an automobile lawfully stopped by the police is a violation of the Fourth Amendment and not justified under the automobile exception.
Court membership
Chief Justice
Warren E. Burger
Associate Justices
William J. Brennan Jr. · Potter Stewart
Byron White · Thurgood Marshall
Harry Blackmun · Lewis F. Powell Jr.
William Rehnquist · John P. Stevens
Case opinions
MajorityPowell, joined by Brennan, Stewart, White, Marshall
ConcurrenceBurger, joined by Stevens
DissentBlackmun, joined by Rehnquist
Laws applied
U.S. Const. amend. IV
Overruled by
California v. Acevedo, 500 U.S. 565 (1991)

Sanders resolved two distinct lines of cases: on the one hand, Carroll v. United States (1925) laid down the automobile exception which allowed for warrantless searches of automobiles; on the other hand, Chadwick did not allow for a warrantless search of luggage. Sanders declined to extend the automobile exception here, again stressing, as in Chadwick, the heightened expectation of privacy in one's luggage.

See also

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