500 U.S. 565 (1991), Supreme Court of the United States
California v. Acevedo is a foundational Fourth Amendment case that harmonized a fractured body of law governing warrantless searches of containers found in automobiles.
When officers have probable cause to believe a specific container within an automobile holds contraband or evidence, may they open and search that container without a warrant under the Fourth Amendment, even if they lack probable cause to search the entire vehicle?
Under the automobile exception to the Fourth Amendment's warrant requirement, police may conduct a warrantless search of an automobile and the containers within it when they have probable cause to believe that contraband or evidence is present. If probable cause is limited to a particular container in the vehicle, officers may search only that container without a warrant. California v. Acevedo overrules United States v. Chadwick and Arkansas v. Sanders to the extent those cases required a warrant to open containers in vehicles where probable cause pertained solely to the container.
Yes. The Fourth Amendment permits police, without a warrant, to search a container found in an automobile when they have probable cause to believe the container holds contraband or evidence, even if they do not have probable cause to search the entire car. The Court reversed the California Court of Appeal.
Acevedo is a cornerstone of the automobile exception. It unifies prior precedent into a single, administrable rule: with probable cause, police may search containers within vehicles without a warrant, but the scope of the search is limited by the object of probable cause. For law students, Acevedo clarifies the relationship among Carroll/Chambers (automobile exception), Ross (scope defined by the object of probable cause), and Chadwick/Sanders (partially overruled). It also offers an important exam-ready insight: if the probable cause is container-specific, officers may open that container but may not rummage through other parts of the vehicle absent additional probable cause.