United States v. Chadwick

Facts

Railroad officers observed two of the defendants, Machado and Leary, load a brown footlocker onto a train bound for Boston. The trunk was unusually heavy for its size, and that it was leaking talcum powder, a substance often used to mask the odor of marijuana. The railroad officers reported it to the federal agents.

When the train arrived in Boston two days later, federal agents placed Machado and Leary under surveillance. The third defendant, Chadwick, then joined Machado and Leary, and they engaged an attendant to move the footlocker outside to Chadwick’s waiting automobile. Machado, Chadwick, and the attendant lifted the 200-pound footlocker into the trunk of the car, while Leary waited in the front seat. At that point, while the trunk of the car was still open and before the car engine had been started, the officers arrested all three of them. The keys to the footlocker were taken from Machado, and officers took it to a federal building. An hour and a half after the arrests, officers searched it and found marijuana. They did not have a search warrant.

They filed a motion to suppress the evidence obtained from the search, and the district court granted it. The appellate court affirmed. The government appealed, arguing that the search of the footlocker falls under the automobile exception to the warrant requirement of the Fourth Amendment. Further, the government argued that warrant protection should extend only to private dwellings and a few other high privacy areas.