Vale v. Louisiana
399 U.S. 30 (1970)

  • The police suspected Vale of being a drug dealer. They waited outside of his house and watched Saucier drive up and honk. Vale came out of the house and acted suspiciously during his conversation with Saucier, leading police to believe that there was a drug deal in progress.
  • The police swooped in and arrested Vale and Saucier in the front yard. They then entered the house and searched, finding a quantity of drugs.
    • The police had an arrest warrant but not a search warrant.
      • Btw, there was no time to get a search warrant because it was an arrest for a crime that the police witnessed. But if they had gone to a magistrate they would have easily been able to show probable cause to get a warrant.
    • The police testified that they saw Saucier swallow something, which they suspected was the drugs he had just bought from Vale. No other drugs were found on Vale or Saucier in the front yard.
  • The Trial Court convicted Vale of drug possession. He appealed.
    • Vale argued that the search of his house was unconstitutional under the 4th Amendment because the police did not have a search warrant.
  • The Louisiana Supreme Court upheld the conviction. Vale appealed.
    • The Louisiana Supreme Court found that the police are allowed to make a search of the “immediate vicinity of the arrest” which included Vale’s house.
  • The US Supreme Court reversed and overturned the conviction.
    • The US Supreme Court found that immediate vicinity means immediate vicinity, which does not include the house.
    • The Court noted that the theory behind the limited search is that an arresting officer may search only the area “within the immediate control” of the person arrested, meaning the area from which he might gain possession of a weapon or destructible evidence.
      • Vale was in the front yard, he couldn’t have gotten to any weapons or destroyed any evidence inside his house.
  • In a dissent, it was argued that the police had probable cause to believe that there were other people inside the house who could have seen Vale’s arrest and might be destroying evidence. Therefore the police did have exigent circumstances to believe evidence was being destroyed, and so a warrantless search would be ok.
    • Is it reasonable to presume that the otherwise innocent people will break the law by destroying evidence?
  • The basic rule here is that a search may take place along with an arrest as long as it is “substantially contemporaneous with the arrest and is confined to the immediate vicinity of the arrest.”
    • “Belief, however well founded, that an article sought is concealed in a dwelling house furnished no justification for a search of that place without a warrant.”