Summary of Illinois v. Lafayette, United States Supreme Court, 1983

Statement of the Case:

Arrested theatre altercator is challenging a search of his purse-type shoulder bag when he was arrested and the bag was inventoried/searched back at the station, leading to his conviction for possession of a controlled substance.

Procedure:

Lower courts ruled this to be an unconstitutional search.

Facts:

Officer arrested disorderly theatergoer and took him to the station.  He had a purse-type bag.  When the officer made the man empty his pockets, he also searched the bag and found 10 amphetamine pills.

Issue:

Whether it violates the 4^th Amendment for police to search the personal items of a person under lawful arrest as part of a routine administrative procedure at a police stationhouse, incident to booking and jailing the man.

Procedural Result:

Judgment reversed for the State.

Holding:

The 4^th Amendment does not prevent the police from searching the personal items of a person under lawful arrest as part of a routine administrative procedure at a police stationhouse, incident to booking and jailing the man.

Reasoning:

• Inventory search is not a search, but an incidental administrative step following arrest and preceding incarceration.
• At a stationhouse, it is proper to remove and list inventory from the person being jailed for the following reasons:
  • Makes a list of the man’s possessions so that false claims are not filed, and theft does not occur.
  • The individual may injure himself or others with dangerous objects that are easily concealed.
  • May assist police in verifying the identity of the arrested party.
• Police do not need any particular fear, as this is a bright-line rule, like in Robinson.