Rawlings v. Kentucky

David Rawlings (defendant) was visiting a home when police arrived with a warrant for one of the home’s residents. The police did not find the resident. During the search, the police smelled marijuana smoke and saw marijuana seeds. Two officers left to get a search warrant, while the remaining officers detained Rawlings and the other occupants of the house. Rawlings was seated on a living-room sofa next to Vanessa Cox, another visitor. Cox’s purse was between them on the sofa. The officers returned with a search warrant, and Cox was ordered to empty her purse onto the coffee table. The contents of her purse included lysergic acid diethylamide (LSD) and several other controlled substances. Rawlings, who had dumped the drugs into Cox’s purse earlier that day, claimed ownership of the drugs. When police searched him, they found $4,500 in cash as well as a knife. Rawlings was charged by the state of Kentucky (plaintiff) with possession with intent to sell the drugs. Rawlings moved to suppress evidence of the drugs on the theory that the search of Cox’s purse had been illegal and that Rawlings had a reasonable expectation of privacy in Cox’s purse because it contained his property. At the suppression hearing, Rawlings admitted that he did not believe the purse would escape search by the police. The motion was denied, and Rawlings was convicted. On appeal, the Supreme Court of Kentucky affirmed the denial of the motion to suppress, holding that Rawlings had not made a sufficient showing that he had a reasonable expectation of privacy in the purse.