Searching and Seizing Automobiles and Baggage
By 1925 the U.S. Supreme Court had clearly decided that the Fourth Amendment required federal police officers to have a warrant before entering a home or the private area of a business. Later, when the Court determined that the Fourteenth Amendment made the Fourth Amendment applicable to the states, this same rule applied to state and local police officers. Next, the Court tried to develop a rule concerning police searches of automobiles that struck the right balance between the needs of law enforcement and the privacy rights of citizens. The main issue was determining when police need a search warrant before they may search or seize an automobile.
In the 1925 case of Carroll v. United States (see p. 83), the Court for the first time applied the Fourth Amendment to the search of an automobile. The case involved the Carroll brothers, notorious bootleggers in Michigan, who were generally known to sell illegal liquor in the Grand Rapids area. When federal agents saw the Carroll brothers driving in the direction of Grand Rapids from Detroit, a known source of illegal liquor smuggled in from Canada, they stopped the Carrolls' car and searched it. Under the upholstery in the back seat the federal agents found cases of liquor. The Carroll brothers were convicted of violating the National Prohibition Act.
The Carroll brothers' attorney argued that the federal agents should have obtained a search warrant before stopping and searching the car. A unani-