Antonio Garcia v. State of Indiana
2016 Ind. LEXIS 30
| Ind. | 2016Background
- Officer Phillip Robinett stopped Antonio Garcia for driving without headlights and discovered Garcia had no valid driver's license; Garcia was lawfully arrested for driving without a license.
- During a routine pat-down incident to arrest, Officer Robinett recovered a silver, cylinder-shaped pill container from Garcia’s pocket and opened it, finding a single pill later identified as hydrocodone for which Garcia had no prescription.
- Garcia moved to suppress the container and its contents, conceding seizure of the closed container was lawful but arguing opening it exceeded the scope of a search incident to arrest under Article 1, Section 11 of the Indiana Constitution.
- The trial court denied the motion; Garcia was convicted of possession of a controlled substance and driving without a license.
- The Indiana Court of Appeals reversed, finding the opening of the container unreasonable under Litchfield balancing; the State sought transfer to the Indiana Supreme Court.
- The Indiana Supreme Court granted transfer and affirmed the trial court, holding opening the container during a search incident to a lawful arrest was reasonable under Article 1, Section 11.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether opening a closed container found on arrestee’s person during a pat-down is permissible as a search incident to arrest under Article 1, Section 11 | State: a lawful custodial arrest authorizes a full search of the person including opening containers found on the arrestee | Garcia: opening the container exceeded the scope of the search incident to arrest; no additional suspicion, exigency, or officer safety justification supported opening it | Held: Opening the container was within the scope of a search incident to arrest and reasonable under Article 1, Section 11 |
| How to apply Indiana’s Litchfield reasonableness factors to a container opened during an arrest search | State: Litchfield factors, read in context of an arrest, weigh in favor of permitting inspection of containers found on person | Garcia: degree of suspicion and intrusion weigh against allowing the opening absent more justification | Held: Under totality and in the context of a lawful arrest, all three Litchfield factors (suspicion, intrusion, law enforcement need) favored the State |
| Whether federal precedents (e.g., Robinson) control Indiana Article 1, Section 11 analysis | State: Robinson and related federal cases are persuasive and support permitting opening of containers incident to arrest | Garcia: Indiana constitution affords broader protections; Robinson should not automatically permit opening without further justification | Held: Federal precedent like Robinson is persuasive; Indiana reaches the same result under Article 1, Section 11 |
| Whether officer’s subjective belief about danger or contraband matters to reasonableness | State: objective circumstances control; officer’s subjective view is immaterial once arrest is lawful | Garcia: lack of subjective fear or specific suspicion undermines reasonableness | Held: Objective reasonableness controls; lack of subjective fear does not render the search unreasonable |
Key Cases Cited
- U.S. v. Robinson, 414 U.S. 218 (search incident to lawful arrest permits inspection of items found on person)
- Weeks v. United States, 232 U.S. 383 (historical recognition of searches incident to arrest)
- Litchfield v. State, 824 N.E.2d 356 (Ind. 2005) (Article 1, §11 reasonableness test balancing three factors)
- Edwards v. State, 759 N.E.2d 626 (Ind. 2001) (post-arrest full search of person; discussion of Robinson)
- Chambers v. State, 422 N.E.2d 1198 (Ind. 1981) (wallet opened as part of search of person incident to arrest)
- Guilmette v. State, 14 N.E.3d 38 (Ind. 2014) (testing/seizing evidence already lawfully seized does not require separate warrant)
- Farrie v. State, 266 N.E.2d 212 (Ind. 1971) (search incident to arrest is lawful regardless of what it reveals)
- Riley v. California, 134 S. Ct. 2473 (2014) (risks posed by unknown items during custodial arrest relevant to search justification)