State v. Brown
401 S.C. 82
S.C.2012Background
- Brown was arrested for open container and a duffel bag containing cocaine was found in the car.
- Officer Williams opened the duffel bag after removing Brown and observed cocaine in a Fritos bag.
- Brown’s suppression motion argued the bag search violated the Fourth Amendment under Gant.
- The trial court admitted the drugs as a search incident to a lawful arrest under Belton.
- The Court of Appeals reversed, applying Gant to suppress the evidence, leading to this certiorari review.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the duffel bag search was lawful under Belton as understood at the time | Brown: search violated Fourth Amendment under Gant | State: search was permissible under Belton | Search lawful under Belton; exclusionary rule not applied |
| Whether Davis and Gant retroactively bar the admission when relied on binding precedent | Brown: retroactive rule invalidates evidence under Gant | State: Davis allows reliance on binding precedent; no deterrence from exclusion | Exclusion not required due to reliance on binding appellate precedent per Davis |
Key Cases Cited
- New York v. Belton, 453 U.S. 454 (U.S. 1981) (allowance of search of passenger compartment incident to arrest)
- Arizona v. Gant, 556 U.S. 332 (U.S. 2009) (two-part vehicle search rule after arrest; limits Belton)
- Davis v. United States, 131 S. Ct. 2419 (U.S. 2011) (exclusionary rule not applied when police rely on binding precedent)
- Narciso v. State, 397 S.C. 24 (S.C. 2012) (Davis applied to pending direct review in SC; exclusionary rule considerations)
- State v. Wright, 391 S.C. 436 (S.C. 2011) (Fourth Amendment framework and exclusions in SC)