Almeida-Sanchez v. United States, 413 U.S. 266 (1973), was a United States Supreme Court case holding that the search of an automobile by the United States Border Patrol without a warrant or probable cause violates the Fourth Amendment. The vehicle was stopped and searched for illegal aliens twenty-five miles () from the Mexican border. The Court approached the search from four views: automobile search, administrative inspection, heavily regulated industry inspection, and border search. As to the validity of the search under the automobile exception, the Court found no justification for the search under the Carroll doctrine because there was no probable cause. As to the validity of the search under various administrative inspection doctrines, the Court found that the officers lacked an area warrant. As to the validity of the heavily regulated industry inspection, the Court found that the doctrine is not applicable to traveling on a state highway. As to the validity of a border search, the Court found that the site of the stop and the entirety of the road on which the stop occurred was too far from the border to be considered a border search.
Background
Condrado Almeida-Sanchez was a Mexican citizen who held a valid American work permit. Shortly after midnight, Border Patrol officers stopped Almeida-Sanchez and thoroughly searched his vehicle. The officers stopped Almeida-Sanchez on California Highway 78 at a point twenty-five air miles north of the Mexican border. Highway 78 ran East to West and did not connect to the border. At the time, Border Patrol efforts to identify individuals who have recently entered the United States without authorization included the following: permanent checkpoints, temporary checkpoints, and roving patrols. Almeida-Sanchez was stopped by a roving patrol. The Border Patrol officers did not have a warrant to stop Almeida-Sanchez, and the United States conceded that the officers did not have probable cause or reasonable suspicion to justify the stop or the subsequent vehicle search.
In searching behind and under the back seat of the vehicle, the officers found marijuana and arrested Almeida-Sanchez. Almeida-Sanchez moved to suppress the marijuana because the officers found it through an unconstitutional search, violating the Fourth Amendment. The United States argued that the Immigration and Nationality Act Section 287(a)(3) authorizes warrantless searches of vehicles within a reasonable distance of the land border. The United States further noted that regulations adopted by the Attorney General define this distance to be within 100 miles.
The District Court for the Southern District of California denied Almeida-Sanchez's motion to suppress. The evidence of the marijuana was admitted and he was convicted of knowingly receiving, concealing and facilitating the transportation of a large quantity of unlawfully imported marijuana. He was sentenced to five years in prison. Almeida-Sanchez appealed his conviction arguing that the search of his car violated the Fourth Amendment. The Ninth Circuit upheld his conviction. Almeida-Sanchez appealed to the Supreme Court of the United States. The Supreme Court reversed.
Supreme Court Opinion
Justice Stewart's majority
Justice Stewart delivered the opinion of the Court. The Supreme Court held that the roving patrol's warrantless search of Almeida-Sanchez's car without probable cause or Almeida-Sanchez's consent violated the Fourth Amendment right to be free from unreasonable searches and seizures. Although there are exceptions to the requirement to get a warrant, the Court held that none of the exceptions applied in this case.
First, the Carroll exception did not apply here. In Carroll v. United States, the Court permitted a warrantless search of a vehicle because officers risked losing evidence if the car left their jurisdiction while they try to secure a warrant. But the officers in Carroll still had probable cause to stop the vehicle and to search it. In this case, the United States conceded that the Border Patrol officers did not have probable cause to stop Almeida-Sanchez or to search his vehicle. The Court wrote that “the Carroll doctrine does not declare a field day for the police in searching automobiles. Automobile or no automobile, there must be probable cause for the search.” Because the United States admitted that the officers did not have probable cause, the Court held that the Carroll exception was not applicable.