Washington v. Chrisman

A campus police officer arrested Carl Overdahl as he was leaving a student dormitory carrying a bottle of gin. The officer believed that Overdahl was underage and asked Overdahl for identification. Overdahl stated that his ID was in his dorm room, and the officer went with Overdahl to his dorm room so that Overdahl could obtain his ID. Chrisman (defendant), Overdahl's roommate, was in the dorm room when Overdahl and the officer arrived. The officer waited at the open door for Overdahl to retrieve his ID, but the officer observed what appeared to be marijuana and a pipe on a table in the room. The officer entered the room and confirmed that the substance was marijuana. The officer then informed Chrisman and Overdahl of their Miranda rights. Both Chrisman and Overdahl waived their rights, and Chrisman produced three additional bags of marijuana. Chrisman and Overdahl then consented to a search of their room, which revealed more marijuana and lysergic acid diethylamide (LSD). Chrisman was charged with felony possession of marijuana and LSD. Chrisman moved to suppress the evidence of the drugs seized in the dorm room. The court denied the suppression motion, and Chrisman was ultimately convicted. The appeals court affirmed the conviction, but the Washington Supreme Court reversed. The court held that although the officer appropriately accompanied Overdahl to the dorm room, the officer had no right to enter the room and seize the drugs without a warrant. The United States Supreme Court granted certiorari.