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United States v. Jacobsen

United States Supreme Court

466 U.S. 109 (1984)

Facts

A package belonging to the Jacobsens (defendants) was damaged by a forklift at a Federal Express warehouse. Federal Express employees, in compliance with a corporate policy concerning insurance claims, opened the package to inspect its contents. On discovering that the package contained a white, powdery substance wrapped in several layers of plastic bags, the Federal Express employees repackaged the substance and called the Drug Enforcement Administration (DEA). DEA agents removed the powder from the box and conducted a field test that identified the powder as cocaine. Based on the result of the field test, agents obtained a warrant to search the address on the package and arrested the Jacobsens for possession of an illegal substance with intent to distribute. The Jacobsens filed a motion to suppress, arguing that the warrant had been obtained pursuant to an illegal search and seizure. The trial court denied the motion, and the Jacobsens were convicted. The court of appeals reversed the conviction, holding that the warrantless test of the white powder had been a significant expansion of the Federal Express employees’ private search of the package and thus had violated the Jacobsens’ Fourth Amendment rights.

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Holding and Reasoning (Stevens, J.)

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Dissent (Brennan, J.)

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