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High Court Strikes Down Pennsylvania Rulings Requiring 'Exigent Circumstances' To Justify Warrantless Searches Of Automobiles

Thursday, 11 July 1996

In a decision that has drawn criticism from civil libertarians, the United States Supreme Court has ruled in a Per Curiam decision that the Pennsylvania Supreme Court was incorrect in requiring police to obtain a warrant before searching an automobile unless "exigent circumstances" were present.

In two separate cases, the Pennsylvania Supreme Court suppressed evidence uncovered in warrantless automotive searches because the "Commonwealth's jurisprudence of the automobile exception has long required both the existence of probable cause and the presence of exigent circumstances to justify a warrantless search." The court maintained that the police had sufficient time in both cases to secure a warrant. Therefore, they held that, "The warrantless search of [a] stationary vehicle violated constitutional guarantees."

The United States Supreme Court concluded that Pennsylvania's interpretation of the "automobile exception of the Fourth Amendment's warrant requirement" was incorrect. The court maintains that an automobile's "ready mobility" is a sufficient circumstance to excuse failure to obtain a search warrant once probable cause has been established. In addition, "the individual [has a] reduced expectation of privacy in an automobile, owing to its pervasive regulation." Therefore, the court affirmed that, "If a car is readily mobile and probable cause exists to believe it contains contraband, the Fourth Amendment thus permits police to search a vehicle without more."

"Essentially, the court has stripped Pennsylvanians of their state constitutional guarantees that provide local citizens with greater protections against warrantless searches of their automobiles unless both probable cause and unforeseen circumstances are present," said NORML Deputy Director Allen St. Pierre. "In it's never-ending fight to assist in the 'War on Drugs,' the Supreme Court has trampled over civil liberties mandated by Pennsylvania's own state constitution."

Justices John Paul Stevens and Ruth Ginsburg dissented on the basis that the Supreme Court lacked jurisdiction over the two cases. "A fair reading of [both cases] demonstrates that the [Pennsylvania Supreme Court's] judgement almost certainly rested upon [an] ... independent consideration of its own Constitution," Stevens wrote. Consequently, "there is no reason for this court to disturb the state court's findings."

The cases are cited as Pennsylvania v. Edwin Labron and Pennsylvania v Randy Lee Kilgore.