Fragile Fern – Cystopteris fragilis

United States v. Robinson, 414 U.S. 218 (1973), was a case in which the United States Supreme Court held that "in the case of a lawful custodial arrest a full search of the person is not only an exception to the warrant requirement of the Fourth Amendment, but is also a reasonable search under that Amendment."

A Washington D.C. Metropolitan police officer stopped a 1965 Cadillac based on reliable information that the driver's operating license had been revoked. All three occupants exited the car, and the officer arrested the driver, Robinson. (For purposes of the Court's opinion, it was assumed that Robinson's full-custody arrest was valid.) The officer proceeded to search Robinson, and felt a package whose contents the officer could not immediately identify. Upon removing the package—a crumpled cigarette packet—and opening it, the officer discovered "14 gelatin capsules of white powder" that turned out to be heroin.

Did the officer's search of the defendant violate the Fourth Amendment?

According to the Court "in the case of a lawful custodial arrest a full search of the person is not only an exception to the warrant requirement of the 4th Amendment, but is also a reasonable search under that Amendment."

• Chimel v. California (1969)
• Virginia v. Moore (2008)
• Arizona v. Gant (2009)
• People v. Diaz (2011)

• Aaronson, David E.; Wallace, Rangeley (1976). "A Reconsideration of the Fourth Amendment's Doctrine of Search Incident to Arrest". Georgetown Law Journal. 64: 53.
• Bradley, Craig M. (1993). "The Court's 'Two Model' Approach to the Fourth Amendment: Carpe Diem!". Journal of Criminal Law and Criminology. 84 (3): 429–461. doi:10.2307/1143960. JSTOR 1143960.
• LaFave, Wayne R. (1974). "'Case-by-Case Adjudication' versus 'Standardized Procedures': The Robinson Dilemma". The Supreme Court Review. 1974: 127–163. doi:10.1086/scr.1974.3108707. JSTOR 3108707.
• Nolasco, Claire (2010). "United States v. Robinson". In Del Carmen, Rolando V.; Hemmens, Craig (eds.). Criminal Procedure and the Supreme Court. Rowman & Littlefield. pp. 104–116. ISBN 9781442201569.

• Text of United States v. Robinson, 414 U.S. 218 (1973) is available from: Justia  Library of Congress  Oyez (oral argument audio)