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Here is an excerpt of the Legal Analysis for

TEXAS V. WHITE

423 U.S. 67 (1975)

LEGAL ANALYSIS: The dissent clearly points out the factual differences between this case and the Chamber case as well as other seminal cases in the seizure of automobiles. See infra.

From Dean’s Law Dictionary under the Carroll doctrine (automobile searches) The Fourth Amendment protects the "right of the people to be secure in their persons, houses, papers, and effects, against unreasonable searches and seizures." Contemporaneously with the adoption of the Fourth Amendment, the First Congress, and, later, the Second and Fourth Congresses, distinguished between the need for a warrant to search for contraband concealed in "a dwelling house or similar place" and the need for a warrant to search for contraband concealed in a movable vessel. See Carroll v. United States, 267 U.S. 132, 151 (1925). See also Boyd v. United States, 116 U.S. 616, 623-624 (1886). In Carroll, this Court established an exception to the warrant requirement for moving vehicles, for it recognized "a necessary difference between a search of a store, dwelling house or other structure in respect of which a proper official warrant readily may be obtained, and a search of a ship, motor boat, wagon or automobile, for contraband goods, where it is not practicable to secure a warrant because the vehicle can be quickly moved out of the locality or jurisdiction in which the warrant must be sought." 267 U.S., at 153. It therefore held that a warrantless search of an automobile based upon probable cause to believe that the vehicle contained evidence of crime in the light of an exigency arising out of the likely disappearance of the vehicle did not contravene the Warrant Clause of the Fourth Amendment. See id. , at 158-159.

The Court refined the exigency requirement in Chambers v. Maroney, 399 U.S. 42 (1970), when it held that the existence of exigent circumstances was to be determined at the time the automobile is seized. The car search at issue in Chambers took place at the police station, where the vehicle was immobilized, sometime after the driver had been arrested. Given probable cause and exigent circumstances at the time the vehicle was first stopped, the Court held that the later warrantless search at the station passed constitutional muster. The validity of the later search derived from the ruling in Carroll that an immediate search without a warrant at the moment of seizure would have been permissible. See Chambers, 399 U.S. at 51. The Court reasoned in Chambers that the police could search later whenever they could have searched earlier, had they so chosen. Id. , at 51-52. Following Chambers, if the police have probable cause to justify a warrantless seizure of an automobile on a public roadway, they may conduct either an immediate or a delayed search of the vehicle.

In United States v. Ross, 456 U.S. 798, decided in 1982, it  held that a warrantless search of an automobile under the Carroll doctrine could include a search of a container or package found inside the car when such a search was supported by probable cause. The warrantless search of Ross' car occurred after an informant told the police that he had seen Ross complete a drug transaction using drugs stored in the trunk of his car. The police stopped the car, searched it, and discovered in the trunk a brown paper bag containing drugs. We decided that the search of Ross' car was not unreasonable under the Fourth Amendment: "The scope of a warrantless search based on probable cause is no narrower - and no broader - than the scope of a search authorized by a warrant supported by probable cause." Id. , at 823. Thus, "[i]f probable cause justifies the search of a lawfully stopped vehicle, it justifies the search of every part of the vehicle and its contents that may conceal the object of the search." Id. , at 825. In Ross, therefore, we clarified the scope of the Carroll doctrine as properly including a "probing search" of compartments and containers within the automobile so long as the search is supported by probable cause. Id. , at 800.  In addition to this clarification, Ross distinguished the Carroll doctrine from the separate rule that governed the search of closed containers. See 456 U.S., at 817. The Court had announced this separate rule, unique to luggage and other closed packages, bags, and containers, in United States v. Chadwick, 433 U.S. 1 (1977). In Chadwick, federal narcotics agents had probable cause to believe that a 200-pound double-locked footlocker contained marijuana. The agents tracked the locker as the defendants removed it from a train and carried it through the station to a waiting car. As soon as the defendants lifted the locker into the trunk of the car, the agents arrested them, seized the locker, and searched it. In this Court, the United States did not contend that the locker's brief contact with the automobile's trunk sufficed to make the Carroll doctrine applicable. Rather, the United States urged that the search of movable luggage could be considered analogous to the search of an automobile. 433 U.S., at 11-12. The Court rejected this argument because, it reasoned, a person expects more privacy in his luggage and personal effects than he does in his automobile. Id. , at 13. Moreover, it concluded that, as "may often not be the case when automobiles are seized," secure storage facilities are usually available when the police seize luggage. Id. , at 13, n. 7. In Arkansas v. Sanders, 442 U.S. 753 (1979), the Court extended Chadwick's rule to apply to a suitcase actually being transported in the trunk of a car. In Sanders, the police had probable cause to believe a suitcase contained marijuana. They watched as the defendant placed the suitcase in the trunk of a taxi and was driven away. The police pursued the taxi for several blocks, stopped it, found the suitcase in the trunk, and searched it. Although the Court had applied the Carroll doctrine to searches of integral parts of the automobile itself, (indeed, in Carroll, contraband whiskey was in the upholstery of the seats, see 267 U.S. at 136), it did not extend the doctrine to the warrantless search of personal luggage "merely because it was located in an automobile lawfully stopped by the police." 442 U.S., at 765. Again, the Sanders majority stressed the heightened privacy expectation in personal luggage, and concluded that the presence of luggage in an automobile did not diminish the owner's expectation of privacy in his personal items. Id. , at 764-765. Cf. California v. Carney, 471 U.S. 386 (1985). In Ross, the Court endeavored to distinguish between Carroll, which governed the Ross automobile search, and Chadwick, which governed the Sanders automobile search. It held that the Carroll doctrine covered searches of automobiles when the police had probable cause to search an entire vehicle, but that the Chadwick doctrine governed searches of luggage when the officers had probable cause to search only a container within the vehicle. Thus, in a Ross situation, the police could conduct a reasonable search under the Fourth Amendment without obtaining a warrant, whereas in a Sanders situation, the police had to obtain a warrant before they searched. In California Acevedo, the Court eliminated the car-container distinction and adopted one rule for automobile searches where no warrant was required.