Stoner v. California

Stoner v. California
Supreme Court of the United States
Argued February 25, 1964 Decided March 23, 1964
Full case name	Joseph Lyle Stoner v. State of California
Docket no.	63-209
Citations	376 U.S. 483 (more) 84 S. Ct. 889; 11 L. Ed. 2d 856
Argument	Oral argument
Opinion announcement	Opinion announcement
Case history
Prior	Conviction affirmed 205 Cal.App.2d 108, 22 Cal.Rptr. 718 (Cal.App., 2d. A.D., 1962); certification denied, 205 Cal.App.2d 116 (Cal., 1962); certiorari granted, 374 U.S. 826
Holding
Warrantless search incident to arrest must be contemporaneous with and in general vicinity of arrest to be reasonable; consent from hotel personnel, even in management, is insufficient to permit search of guest room without warrant. California Court of Appeal, Second District, reversed and remanded.
Court membership
Chief Justice Earl Warren Associate Justices Hugo Black · William O. Douglas Tom C. Clark · John M. Harlan II William J. Brennan Jr. · Potter Stewart Byron White · Arthur Goldberg
Case opinions
Majority	Stewart, joined by Warren, Black, Douglas, Clark, Brennan, White, Goldberg
Concur/dissent	Harlan
Laws applied
U.S. Const. amend. IV

Stoner v. California, 376 U.S. 483 (1964), is a United States Supreme Court decision involving the Fourth Amendment. It was a criminal case appealed from the California Courts of Appeal after the California Supreme Court denied review. The case extended the situations under which search warrants are required as they reversed a robbery conviction made on the basis of evidence obtained in violation of the holding.

The petitioner, Joey Stoner, had been arrested following a 1960 supermarket robbery in the Los Angeles area. Eyewitness accounts and evidence left at the scene led the police to a hotel elsewhere in the region where Stoner was staying. Two days later, detectives went to the hotel and, with the desk clerk's permission, searched the room and found further evidence linking him to the robbery. Stoner was arrested two days later in Nevada, and extradited. The evidence from the hotel room was used to convict him of the robbery at trial. Stoner unsuccessfully challenged the admissibility of the evidence at trial and on appeal, since police had lacked a warrant and relied on the clerk's permission. The appeals court held that the search was incident to arrest and thus permissible.

Writing for the Court, Justice Potter Stewart reaffirmed two previous holdings: The first, Agnello v. United States (1925) held such warrantless searches are constitutional only to the extent that they take place at the same time, and in the same place, as the arrest. Two other cases established that the hotel clerk's consent did not permit police to search the room without a warrant. "[A] guest in a hotel room is entitled to constitutional protection against unreasonable searches and seizures" Stewart wrote. "That protection would disappear if it were left to depend upon the unfettered discretion of an employee of the hotel." It did not matter that hotel staff might be permitted to enter the room as that was merely for the limited purpose of cleaning and maintenance. The only other opinion was Justice John Marshall Harlan II, who concurred in the holding but dissented from the disposition reversing the conviction. He would have left it to California's courts to decide whether the admission of the hotel-room evidence was harmless error, as the Court had done in similar circumstances in Fahy v. Connecticut.

The reaffirmation of the earlier rulings was necessitated by the Mapp v. Ohio decision a few years earlier, which extended the exclusionary rule under which unlawfully obtained evidence is inadmissible at trial, to the states as well as the federal government. It came at a time when the Warren Court was beginning to rethink and provide exceptions to the traditional Fourth Amendment doctrine that only those with a possessory or proprietary interest in what was searched had standing to challenge the constitutionality of the search. Several years later, in Katz v. United States, the Court abandoned that doctrine entirely in favor of the reasonable expectation of privacy test now in use.