United States V. Place Case Study

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United States v. Place, 462 U.S. 696 (1983) Capsule Summary: Seizing a person’s luggage for an extended period until a warrant is obtained violates the Fourth Amendment as beyond the limits of a Terry stop, but, a sniff by a narcotics dog does not constitute a search for Fourth Amendment purposes. Facts: The respondent Raymond Place was stopped by Federal Agents (DEA) upon his arrival into LaGuardia Airport on a Friday afternoon. The respondent refused to consent to the search of his luggage. His luggage was seized by the agents under suspicion they contained narcotics. The respondent was informed the agents would be obtaining a search warrant from a judge. The luggage was then transferred to Kennedy Airport where the bags were sniffed by drug detection dogs approximately 90 minutes after the initial seizure. The dogs performed a “sniff” and detected…show more content…
696, 709] suspect 's custody, we think the limitations applicable to investigative detentions of the person should define the permissible scope of an investigative detention of the person 's luggage on less than probable cause. Under this standard, it is clear that the police conduct here exceeded the permissible limits of a Terry-type investigative stop.” “In these respects, the canine sniff is sui generis. We are aware of no other investigative procedure that is so limited both in the manner in which the information is obtained and in the content of the information revealed by the procedure.” Significance: The Supreme Court here expresses that governmental conduct like drug dog sniffing that can reveal whether a substance is contraband, yet no other private fact, does not compromise any privacy interest, and therefore is not a search subject to the Fourth Amendment. Terry v. Ohio permits only brief investigative stops and extremely limited searches based on reasonable suspicion including seizures of property independent of the seizure of the
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