United States v. Mendenhall
United States Supreme Court
446 U.S. 544 (1980)
- Written by Sarah Venti, JD
Facts
Shortly after 22-year-old Sylvia Mendenhall (defendant) landed at Detroit Metropolitan Airport, she was approached by two plainclothes Drug Enforcement Administration (DEA) agents. The agents, who believed Mendenhall was acting consistently with someone carrying unlawful narcotics, identified themselves and asked to see Mendenhall’s ticket and identification. The name on Mendenhall’s driver’s license did not match her ticket, and Mendenhall admitted she was in California only briefly before flying to Detroit. The agents then specifically identified themselves as narcotics agents, and Mendenhall became visibly nervous. The agents asked Mendenhall to accompany them to the DEA’s airport office for further questioning, and she complied. Once there, an agent asked Mendenhall if she would allow a search of her person and purse, informing her that she had the right to decline. Mendenhall consented. When a female officer arrived to search Mendenhall’s person, she again obtained Mendenhall’s consent. As Mendenhall undressed, Mendenhall removed two small packages from her undergarments, one of which contained heroin. Mendenhall was then arrested and charged with possession of heroin with intent to distribute. Mendenhall moved to suppress evidence of the heroin, arguing that it was acquired via an unconstitutional search and seizure. The district court denied the motion on the basis that Mendenhall’s consent to the search was voluntary. Mendenhall was then convicted. The court of appeals reversed, finding that Mendenhall’s consent was not voluntary because it stemmed from an improper seizure. The United States Supreme Court granted certiorari.
Rule of Law
Issue
Holding and Reasoning (Stewart, J.)
Concurrence (Powell, J.)
Dissent (White. J.)
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