Limpuangthip v. United States
District of Columbia Court of Appeals
932 A.2d 1137 (2007)
- Written by Jennifer Flinn, JD
Facts
Jason Limpuangthip (defendant) was a student at George Washington University, a private university in Washington, D.C. Limpuangthip lived in a dormitory on campus. Before moving into the dormitory, Limpuangthip signed an agreement stating that university officials could enter his dorm room and inspect for violations of university regulations or suspected criminal activity. University police officers received an anonymous tip that Limpuangthip had illegal drugs in his dorm room. University police officers were special police officers (SPOs) deputized to protect the property of the SPOs’ private employers. SPOs were under the direction and control of the university. SPOs had similar arrest power to regular police officers, provided the SPOs were on their employer’s property. After receiving the anonymous tip, Penny Davis, the residential assistant (RA) for Limpuangthip’s dormitory, conducted an administrative search of Limpuangthip’s dorm room. Two university SPOs accompanied Davis during the search but did not conduct any of the search. The SPOs were in full uniform. While Davis searched the room, Limpuangthip arrived and showed Davis some of Limpuangthip’s drugs and drug paraphernalia. Davis found additional drugs and paraphernalia in Limpuangthip’s bedroom. The SPOs provided evidence bags for the drugs and paraphernalia. Limpuangthip was charged with possession and intent to distribute drugs and paraphernalia. At trial, Limpuangthip argued that the evidence found during Davis’s search must be suppressed because the search violated the Fourth Amendment. The trial court disagreed and convicted Limpuangthip after a bench trial. Limpuangthip appealed.
Rule of Law
Issue
Holding and Reasoning (Belson, J.)
What to do next…
Here's why 815,000 law students have relied on our case briefs:
- Written by law professors and practitioners, not other law students. 46,300 briefs, keyed to 988 casebooks. Top-notch customer support.
- The right amount of information, includes the facts, issues, rule of law, holding and reasoning, and any concurrences and dissents.
- Access in your classes, works on your mobile and tablet. Massive library of related video lessons and high quality multiple-choice questions.
- Easy to use, uniform format for every case brief. Written in plain English, not in legalese. Our briefs summarize and simplify; they don’t just repeat the court’s language.