Coolidge v. New Hampshire

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Coolidge v. New Hampshire
Seal of the United States Supreme Court.svg
Argued January 12, 1971
Decided June 21, 1971
Full case nameEdward Coolidge v. New Hampshire
Citations403 U.S. 443 ( more )
91 S. Ct. 2022; 29 L. Ed. 2d 564
Case history
Prior109 N.H. 403, 260 A.2d 547 (1969); cert. granted, 399 U.S. 926(1970).
Holding
The warrant for the search and seizure of petitioner's automobile did not satisfy the requirements of the Fourth Amendment, because it was not issued by a "neutral and detached magistrate."
Court membership
Chief Justice
Warren E. Burger
Associate Justices
Hugo Black  · William O. Douglas
John M. Harlan II  · William J. Brennan Jr.
Potter Stewart  · Byron White
Thurgood Marshall  · Harry Blackmun
Case opinions
MajorityStewart (Part III), joined by Burger, Douglas, Harlan, Brennan, Marshall
MajorityStewart (Parts I, II-D), joined by Douglas, Harlan, Brennan, Marshall
PluralityStewart (Parts II-A, II-B, II-C), joined by Douglas, Brennan, Marshall
ConcurrenceHarlan
Concur/dissentBurger
Concur/dissentBlack, joined by Burger, Blackmun (as to Parts II and III and a portion of Part I)
Concur/dissentWhite, joined by Burger
Laws applied
U.S. Const. amend. IV
Superseded by
Horton v. California , 496 U.S. 128 (1990).

Coolidge v. New Hampshire, 403 U.S. 443 (1971), was a United States Supreme Court case dealing with the Fourth Amendment and the automobile exception.

Contents

The state sought to justify the search of a car owned by Edward Coolidge, suspected of killing 14-year-old Pamela Mason in January 1964, on three theories: automobile exception, search incident to arrest, and plain view.

Facts

14-year-old Pamela Mason of Manchester, New Hampshire placed an ad in the window of a local merchant offering to babysit. On January 13, 1964, she was picked up by a man who had called her, saying that he needed a babysitter. He picked her up to take her to the alleged babysitting location but she was never seen again. Eight days later, Mason was found stabbed and shot to death in a snowbank near Manchester, New Hampshire. The state Attorney General took charge of police activities relating to the murder. When the police applied for a warrant to search suspect Coolidge's automobile, the Attorney General, acting as a justice of the peace, authorized it. Additionally, local police had taken items from Coolidge's home during the course of an interview with the suspect's wife. Coolidge was found guilty and sentenced to life imprisonment.

Opinion of the Court

In a decision in which a number of justices chose to concur in part and dissent in part, the Court held that the searches and seizures of Coolidge's property were unconstitutional. Justice Stewart's opinion held that the warrant authorizing the seizure of Coolidge's automobile was invalid because it was not issued by a "neutral and detached magistrate." Justice Stewart also rejected New Hampshire's arguments in favor of making an exception to the warrant requirement. Justice Stewart held that neither the "incident to arrest" doctrine nor the "plain view" doctrine justified the search, and that an "automobile exception" was inapplicable. The Court noted that although the "automobile exception" exists, "the word 'automobile' is not a talisman in whose presence the fourth amendment fades away and disappears...".

Aftermath

Coolidge was released from prison in 1991[ why? ] maintains his innocence in Mason's murder and the other murders he was suspected in. [1]

Related Research Articles

Fourth Amendment to the United States Constitution 1791 amendment prohibiting unreasonable searches and seizures

The Fourth Amendment to the United States Constitution is part of the Bill of Rights. It prohibits unreasonable searches and seizures. In addition, it sets requirements for issuing warrants: warrants must be issued by a judge or magistrate, justified by probable cause, supported by oath or affirmation, and must particularly describe the place to be searched and the persons or things to be seized.

Search and seizure Police power to confiscate any relevant evidence found in connection to a crime

Search and seizure is a procedure used in many civil law and common law legal systems by which police or other authorities and their agents, who, suspecting that a crime has been committed, commence a search of a person's property and confiscate any relevant evidence found in connection to the crime.

United States v. Ross, 456 U.S. 798 (1982), was a search and seizure case argued before the Supreme Court of the United States. The high court was asked to decide if a legal warrantless search of an automobile allows closed containers found in the vehicle to be searched as well. The appeals court had previously ruled that opening and searching the closed portable containers without a warrant was a violation of the Fourth Amendment, even though the warrantless vehicle search was permissible due to existing precedent.

Stanley v. Georgia, 394 U.S. 557 (1969), was a United States Supreme Court decision that helped to establish an implied "right to privacy" in U.S. law, in the form of mere possession of obscene materials.

In the United States, the plain view doctrine is an exception to the Fourth Amendment's warrant requirement that allows an officer to seize evidence and contraband that are found in plain view during a lawful observation. The doctrine is also regularly used by TSA officers while screening persons and property at U.S. airports.

Chimel v. California, 395 U.S. 752 (1969), is a 1969 Supreme Court of the United States case. In Chimel, the Court held that police officers arresting a person at home could not search the entire home without a search warrant, but police may search the area within immediate reach of the person. The rule on searches incident to a lawful arrest within the home is now known as the Chimel Rule.

South Dakota v. Opperman, 428 U.S. 364 (1976), elaborated on the community caretaking doctrine. Under the Fourth Amendment, "unreasonable" searches and seizures are forbidden. In addition to their law-enforcement duties, the police must engage in what the court has termed a community caretaking role, including such duties as removing obstructions from roadways to ensure the free flow of traffic. When the police act in this role, they may inventory cars they have seized without "unreasonably" searching those cars.

Payton v. New York, 445 U.S. 573 (1980), was a United States Supreme Court case concerning warrantless entry into a private home in order to make a felony arrest. The Court struck down a New York statute providing for such warrantless entries because the Fourth Amendment draws a firm line at the entrance to the house. Absent exigent circumstances, that threshold may not be reasonably crossed without a warrant. The court, however, did specify that an arrest warrant would have sufficed for entry into the suspect's residence if there had been reason to believe that the suspect was within the home.

Welsh v. Wisconsin, 466 U.S. 740 (1984), was a 1983 case before the US Supreme Court determining whether a warrantless arrest violates the Fourth Amendment protection against unlawful search and seizure.

Minnesota v. Dickerson, 508 U.S. 366 (1993), was a decision by the Supreme Court of the United States. The Court unanimously held that, when a police officer who is conducting a lawful patdown search for weapons feels something that plainly is contraband, the object may be seized even though it is not a weapon. By a 6-to-3 vote, however, the court held that the officer in this case had gone beyond the limits of a lawful patdown search before he could determine that the object was contraband, making the search and the subsequent seizure unlawful under the Fourth Amendment.

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California v. Carney, 471 U.S. 386 (1985), was a United States Supreme Court case which held that a motor home was subject to the automobile exception to the search warrant requirement of the Fourth Amendment to the United States Constitution because the motor home was readily movable.

Horton v. California, 496 U.S. 128 (1990), was a United States Supreme Court case in which the Court held that the Fourth Amendment does not prohibit the warrantless seizure of evidence which is in plain view. The discovery of the evidence does not have to be inadvertent, although that is a characteristic of most legitimate plain-view seizures. The opinion clarified the plain view doctrine of the Court's Fourth Amendment analysis.

Cupp v. Murphy, 412 U.S. 291 (1973), was a United States Supreme Court case in which the Court upheld a murder conviction notwithstanding a challenge that the evidence upon which guilt was based was obtained in violation of the Fourth and Fourteenth Amendments of the United States Constitution. The court held that in view of the station-house detention upon probable cause, the very limited intrusion of scraping the defendant's fingernails for blood and other material, undertaken to preserve highly evanescent evidence, did not violate the Fourth and Fourteenth Amendments.

Stoner v. California, 376 U.S. 483 (1964), is a United States Supreme Court decision involving the Fourth Amendment. It was a criminal case appealed from the California Courts of Appeal after the California Supreme Court denied review. The case extended the situations under which search warrants are required as they reversed a robbery conviction made on the basis of evidence obtained in violation of the holding.

Kentucky v. King, 563 U.S. 452 (2011), was a decision by the US Supreme Court, which held that warrantless searches conducted in police-created exigent circumstances do not violate the Fourth Amendment as long as the police did not create the exigency by violating or threatening to violate the Fourth Amendment.

United States v. Watson, 423 U.S. 411 (1976), was a case decided by the Supreme Court of the United States that decided that a warrantless arrest in public and consenting to a vehicle search did not violate the Fourth Amendment.

Birchfield v. North Dakota, 579 U.S. ___ (2016), was a case in which the Supreme Court of the United States held that the search incident to arrest doctrine permits law enforcement to conduct warrantless breath tests but not blood tests on suspected drunk drivers.

Caniglia v. Strom, 593 U.S. ___ (2021), was a United States Supreme Court case related to the Fourth Amendment to the United States Constitution's "community caretaking" exception.

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