Carroll v. United States, 267 U.S. 132 (1925)

The National Prohibition Act, also known as the Volstead Act, was passed by Congress in 1919 and prohibited the manufacturing, transportation, and sale of alcoholic beverages. On January 16, 1920, the Volstead Act came into force as the Eighteenth Amendment, later repealed in 1933 by the Twenty-first Amendment.
George Carroll and John Kiro were indicted and convicted for transporting intoxicating spirituous liquor in an automobile in the amount of 68 quarts of whiskey and gin in violation of the National Prohibition Act. Carroll and Kiro contended that the search of their automobile and the discovery of the alcohol was the product of an illegal search and seizure in violation of their Fourth Amendment rights.
On September 21, 1921, three men, Carroll, Kiro, and Kruska entered an apartment in Grand Rapids, Michigan, and met three undercover federal prohibition agents, Cronewett, Scully, and Thayer. Cronewett, using an alias, was introduced to Carroll and Kiro, and stated he wanted to buy three cases of whiskey. Carroll and Kiro stated that they had to go east of Grand Rapids to obtain the alcohol and would be back in about an hour. After the time had passed, Kruska returned in an Oldsmobile roadster, the registration number of which Cronewett noted, and stated they could not get the alcohol that night but would return the following day to deliver it. The sellers never returned.
Cronewett and his colleagues maintained patrol on the road between Grand Rapids and Detroit, looking for violators of the National Prohibition Act as part of their regular duties. On October 6, 1921, Carroll and Kiro passed Cronewett and Scully, who were breaking for lunch, in the same Oldsmobile Roadster the agents had noticed a month prior. The agents engaged in a pursuit, but lost the men in East Lansing. More than two months later, on December 15, 1921, Carroll and Kiro again passed the agents. This time the agents were able to catch the two men east of Grand Rapids. Upon stopping them, the agents searched the roadster and found 68 bottles of liquor behind the upholstery of the seats. The two men were arrested.
The question before the Supreme Court was whether the search and seizure of the alcohol in this case violated Carroll and Kiro’s Fourth Amendment rights. Chief Justice Taft delivered the opinion of the Court, including an extensive review of statutory and case law. These references demonstrated that the guaranty of the Fourth Amendment right against illegal search and seizures had long recognized a distinction between the search of a home or structure and that of a vehicle or ship. The distinction is based on the practicability of obtaining a search warrant. The Court demonstrated that it was easier to obtain a warrant for a structure, whereas it was not practicable to secure a warrant for a moveable object like a vehicle, because the vehicle can be quickly moved out of the locality or jurisdiction in which the warrant must be sought.
Next the Court determined under what circumstances a warrantless search of a vehicle might be made. The majority stated that it would be intolerable and unreasonable if a prohibition agent were authorized to stop every automobile on the chance of finding liquor, and thus subject all persons lawfully using the highways to the inconvenience and indignity of such a search. Those entitled to use the public highways have a right to free passage without interruption or search unless probable cause for believing that their vehicles are carrying contraband or illegal merchandise is known to a competent official who is authorized to make searches. In this case, the agents had probable cause or reasonable basis to believe that Caroll and Kiro were transporting alcohol. They appeared in the same vehicle that they had used in October; were followed into a neighborhood notorious for manufacturing and importing illegal spirits; and, had been seen on different occasions making the trip between Detroit and Grand Rapids. It was clear, according to the Court, that in this case the officers had justification for the search and seizure. The facts and circumstances within their knowledge and the trustworthy information were sufficient in themselves to establish a reasonable belief that liquor was being transported in the automobile which they had stopped and searched. Therefore, in this case, Carroll and Kiro’s Fourth Amendment rights were not violated. The search and seizure of the vehicle were warranted by the inherent mobility of the vehicle and by the probable cause the officers had that the two men were transporting alcohol.