United States v. Michael Matthews
532 F. App'x 211
3rd Cir.2013Background
- Police surveilled a check-cashing store after a tip; officers approached two suspicious men and detained Michael Matthews, who carried a green-and-white backpack.
- Officers frisked Matthews, found no weapons on his person, ran a warrants check, and arrested him on two outstanding bench warrants.
- Matthews was handcuffed and placed in the locked back seat of a squad car; while he was secured, Officer Pomeroy opened and searched his backpack on the street, finding gloves, duct tape, and a .22-caliber handgun.
- Matthews moved to suppress the backpack evidence as a warrantless search in violation of the Fourth Amendment; the Government defended the search as necessary for officer safety, as an inventory search under Philadelphia Policy 99-14, or inevitably discoverable at booking.
- The District Court denied suppression, concluding the stop and arrest were lawful and that the search was an inventory search (or at least that the items would have been inevitably discovered). Matthews appealed; the Third Circuit affirmed.
Issues
| Issue | Plaintiff's Argument (Matthews) | Defendant's Argument (Government) | Held |
|---|---|---|---|
| Lawfulness of initial stop/arrest | Stop was illegal, so evidence is fruit of poisonous tree | Stop was supported by reasonable suspicion; arrest valid on outstanding warrants | Stop and arrest lawful (Matthews did not contest arrest ruling on appeal) |
| Search-incident-to-arrest exception | Warrantless search of backpack was not incident to arrest because Matthews was secured and could not access it | Search-incident-to-arrest sometimes permits searching containers for officer safety/evidence | Rejected — no reasonable possibility Matthews could access backpack while handcuffed in locked car; Chimel/Gant principles apply |
| Inventory-search under Policy 99-14 | Policy was not followed; Pomeroy did not inventory items at scene; policy is internally inconsistent and gives officers excessive discretion | Search was pursuant to departmental practice and for officer safety; bag would be inventoried at station | District Court erred to treat the street search as an authorized inventory search under Policy 99-14; policy is inconsistent and officer did not follow procedures |
| New exception: search incident to transportation of arrestee | No warrant should permit searching luggage at scene absent established inventory procedures | Searching luggage that must accompany an arrestee to the station is reasonable for officer safety and caretaking; akin to inventory/search for transportation safety | Third Circuit adopts a narrow rule: when a valid public arrest requires transporting an arrestee and the arrestee’s luggage must accompany him, police may search that luggage before transport as reasonable under the Fourth Amendment (limited to this context) |
| Inevitable-discovery alternative | Suppression required because search unconstitutional | Evidence would inevitably have been discovered during lawful booking inventory at station | Court agrees evidence would inevitably have been discovered; admissible on that ground as alternative basis |
Key Cases Cited
- Arizona v. Gant, 556 U.S. 332 (warrantless searches incident to arrest limited to arrestee's immediate control)
- Chimel v. California, 395 U.S. 752 (search-incident-to-arrest scope: area within immediate control)
- United States v. Chadwick, 433 U.S. 1 (warrantless searches of luggage with probable cause are generally unconstitutional)
- California v. Acevedo, 500 U.S. 565 (clarified container-search rules)
- South Dakota v. Opperman, 428 U.S. 364 (inventory searches of impounded vehicles reasonable under standard procedures)
- Illinois v. Lafayette, 462 U.S. 640 (inventory searches at stationhouse of arrestee’s effects permissible under established procedures)
- Florida v. Wells, 495 U.S. 1 (inventory policies must limit officer discretion to prevent searches becoming investigatory)
- Maryland v. King, 569 U.S. 435 (balancing diminished privacy interests of arrestees against important government interests)
- United States v. Mundy, 621 F.3d 283 (3d Cir.) (inventory procedures must limit discretion as to whether and scope of search)
- United States v. Shakir, 616 F.3d 315 (3d Cir.) (reasonable-possibility standard for whether arrestee could access container)
- Nix v. Williams, 467 U.S. 431 (inevitable discovery doctrine)