Supreme Court of the United States

Texas v. Brown

April 19, 1983460 U.S. 730

Summary

The Court reversed the suppression ruling because the officer lawfully observed a balloon in the automobile and had probable cause to believe it contained narcotics. The plain-view doctrine requires lawful access and probable cause connecting the object to criminal activity, not near certainty that the object is contraband. On the facts, the checkpoint stop, flashlight observation, officer's experience, and surrounding circumstances justified the warrantless seizure.

Holding

  • Jurisdiction over the state-court judgment. The Court had jurisdiction because the state court's decision rested on its interpretation of the Fourth Amendment rather than on an independent and adequate state-law ground.
  • Lawful access and observation under the plain-view doctrine. The officer's checkpoint stop and observation of the vehicle's interior and open glove compartment were lawful and did not constitute a search, so the lawful-access requirement for a plain-view seizure was satisfied.
  • Probable cause and the incriminating nature of the balloon. A plain-view seizure requires probable cause to associate the item with criminal activity, not near certainty or actual knowledge that it is contraband. The officer had probable cause to seize the balloon because of its distinctive packaging, his narcotics experience, corroborating testimony, and the drug-related items visible in the glove compartment.

Docket 81-419

Cited authorities

  • CA10

Cited by