State v. Burroughs

Summary

The Supreme Court of Ohio held that the single-purpose-container exception to the Fourth Amendment warrant requirement did not authorize police to search a closed bookbag found in a home during an arrest. Because the bookbag was not a container whose contents were apparent from its distinctive characteristics and no exigent circumstances existed, the officers were required to obtain a warrant. The court reversed the appellate judgment, vacated the conviction, and remanded with instructions to suppress the evidence.

Holdings

1. A warrantless search of a closed container ordinarily violates the Fourth Amendment unless a specific exception to the warrant requirement applies; probable cause alone does not justify opening the container absent exigent circumstances.
2. The single-purpose-container exception applies only when a container's distinctive configuration, transparency, or other characteristics make its illegal contents readily apparent, effectively placing those contents in plain view. A common bookbag is not a single-purpose drug container, and the visible portion of an empty baggie did not make its contents obvious.

Questions Presented

1. Whether the warrantless search of a closed bookbag inside a home was reasonable under the Fourth Amendment.
2. Whether the single-purpose-container exception to the warrant requirement applied because part of a plastic baggie was visible in the bookbag's zipper.

Disposition

reversed_and_remanded