Petition for Writ of Certiorari — California v. Acevedo

“~ FILED

30

| JOSEPH F. SPANIOL, JR.

IN THE CLERK

SUPREME COURT OF THE UNITED

89-1690 j|. frees

October Term, 1989

PEOPLE OF THE STATE OF CALIFORNIA,

Petitioner,

Vv.

CHARLES STEVEN ACEVEDO,

Respondent.

PETITION FOR WRIT OF CERTIORARI

JOHN K. VAN DE KAMP,

Attorney General of the

State of California

RICHARD B. IGLEHART,

Chief Assistant Attorney

General

HARLEY D. MAYFIELD, Senior

Assistant Attorney General

FREDERICK R. MILLAR JR.,

Supervising

Deputy Attorney General :

ROBERT M. FOSTER, Supervising

Deputy Attorney General

110 West A Street, Suite 700

San Diego, California 92101

Telephone: (619) 237-7852

Attorneys for Petitioner

e 4. «

QUESTIONS PRESENTED

1. The issue presented in this

petition is the exact question that this

Court deadlocked on in Oklahoma v.

Castleberry, 471 U.S. 146, (1985), namely,

whether, under the Fourth Amendment

principles set forth in United States v.

Ross, 456 U.S. 798, (1982), when an

officer has probable cause to believe that

there is contraband in a specific

container within a vehicle, is he required

to obtain a search warrant for that

container or may he search the container

for contraband without a warrant?

2. Did this Court’s decision in

United States v. Ross, supra, overrule or

limit United States v. Chadwick, 433 U.S.

1, (1977)?

_ ii. -

OPINIONS BELOW

JURISDICTION

CONSTITUTIONAL PROVISIONS INVOLVED

STATEMENT OF THE CASE

HOW THE FEDERAL QUESTION IS PRESENTED

STATEMENT OF FACTS

ARGUMENT

THE SEARCH OF THE PAPER LUNCH

BAG IN THE TRUNK OF THE VEHICLE

WAS JUSTIFIED UNDER THE

AUTOMOBILE EXCEPTION TO THE

FOURTH AMENDMENT WARRANT

REQUIREMENT

CONCLUSION

Pages

ocUlC Olle

13

13

29

- iii. -

CASES

Arkansas v. Sanders

442 U.S. 753, (1979)

Carroll v. United States

267 U.S. 132, (1925)

Caétleberry v. State

678 P.2d 720, (Okla.Crim.App.

Chambers v. Maroney

399 U.S. 42, (1970)

Colorado v. Bannister

449 U.S. 1, (1980)

Dunaway v. New York

442 U.S. 200 (1979)

Florida v. Royer

460 U.S. 491, (1983)

Michigan v. Thomas

458 U.S. 259 (1982)

1984)

- iv. -

Oklahoma v. Castleberry

471 U.S.

146,

Peopie v. Acevedo

216 Cal.App.3d 586,

Texas v.

423 U.S.

White

67, (1975)

(1985)

(1989)

United States v. Belton

453 U.S.

454,

(1981)

United States v. Chadwick

433 U.S.

1, (1977)

United States v. Ross

456 U.S. 798, (1982)

OTHER AUTHORITIES

LaFave,

Second Edition,

Section 7.2(d), page 58 (1987)

Search and Seizure,

14

14, 15

16

23

13, 19, 25

21

ee

IN THE

SUPREME COURT OF THE UNITED STATES

October Term, 1989

PEOPLE OF THE STATE OF CALIFORNIA,

Petitioner,

Vv.

CHARLES STEVEN ACEVEDO,

Respondent.

PETITION FOR WRIT OF CERTIORARI

Petitioner, State of California,

respectfully prays that a writ of

certiorari be issuea to review the

judgment and opinion of the Caiifornia

Court of Appeal, Fourth Appellate

District, Division Three, issued on

December 12, 1989.

OPINIONS BELOW

The opinion of the California Court

of Appeal, Fourth Appellate District,

— we

—

Division Three is reported at 216

Cal.App.3d 586 and 265 California Reporter

23 and appears as Appendix A (pages A-1

through A-21).

The first order modifying the

concurring opinion is also reported at 216

Cal.App.3d 586 and 265 California Reporter

23 and appears as Appendix B (pages A-23

through A-25).

The first order modifying the

majority opinion is also reported at 216

Cal.App.3d 586 and 265 California Reporter

23 and appears as Appendix C (pages A-27

through A-28).

The second order modifying the

concurring opinion is also reported at 216

Cal.App.3d 586 and 265 California Reporter

23 and appears as Appendix D (pages A-30

through A-31).

The order of the Supreme Court of

California denying Petitioner’s petition

for review on direct appeal wes entered in

« 3. «

the Official Minutes of that court and

reported in the Official Advance Sheets of

the California Supreme Court. The minute

entry is reproduced in Appendix E at page

A-33.

JURISDICTION

Petitioner invokes the jur‘sdiction

of this Court, under Title 28, United

States Code, section 1257(3) to review a

judgment of the California Court of

Appeal, Fourth Appellate District,

Division Three which was entered on

December 12, 1989. The California Supreme

Court denied review in this case on

March 15, 1990. The present petition for

writ of certiorari is filed within the

required 90 day period following the final

entry of judgment. The judgment of the

Court of Appeal became final for the

purposes of this Court with the denial of

review by the California Supreme Court on

March 15, 1990. (Market Street Railroad

———

ao OF Be

e 4. «

Co. v. Railroad Commission, 324 U.S. 548,

550-552, (1944). Thus, the instant

judgment is a final decision rendered by

the highest court of the State of

California interpreting rights under the

United States Constitution.

CONSTITUTIONAL PROVISIONS INVOLVED

United States Constitution, Amendment

IV:

“The right of the people to

be secure in their persons,

houses, papers and effects,

against unreasonable searches

and seizures, shall not be

violated, and no warrants shall

issue, but upon probable cause,

supported by oath or

affirmation, and particularly

describing the place to be

searched, and the persons or

things to be seized."

STATEMENT OF THE CASE

In an information filed by the

District Attorney of Orange County,

California, on June 24, 1988, respondent

and a co-defendant were charged with one

count of possession of marijuana for sale

OS ee

e 8. «

in violation of California Health and

Safety Code section 11359. (CT 2.)*

On this same date respondent was

arraigned in the Orange County Superior

Court and entered a plea of not guilty to

the charges. (CT 1.) Respondent’s

motions to suppress evidence pursuart to

California Penal Code sections 995 and

1538.5 were heard and denied on October 7,

1988. (CT 77.)

On October 12, 1988, as part of a

plea bargain, the information was amended

to add a second count of possession for

sale in violation of California Health and

Safety Code section 11357, subdivision

(c). Respondent then entered a plea of

guilty to both counts. (CT 78; RT 40-41.)

1. “CT” refers to the Clerk’s

Transcript of the trial court’s

documents and orders. "RT" refers to

the reporter’s transcript of the trial

court proceedings. Both documents were

included as part of the official record

before the California Court of Appeal

and California Suprete Court.

e 6. «

On this same date, respondent was

granted probation on certain terms and

conditions including 30 days in custody

and a $100 fine. (CT 79.)

Respondent’s notice of appeal was

filed on November 10, 1988. (CT 83.) In

a published decision filed on

December 12, 1989, the Court of Appeal,

Fourth Appellate District, Division Three,

reversed with directions the judgment of

the Superior Court and held that the

search of the paper bag was illegal.

(App. A.) Modifications to the opinion

that did not change the result were issued

on December 20 and 29, 1989, and

January 3, 1990. (Apps. B, C and D.) On

March 15, 1990, the California Supreme

Court denied petitioner’s petition for

direct review. (App. E.)

In the Orange County, California

Superior Court, respondent moved to

~— a

suppress evidence on the ground that the

paper bag found in the trunk of his car

was improperly searched under the Fourth

Amendment without a warrant. (CT 49-53.)

The trial court denied the motion to

suppress evidence. (CT 77.)

The California Court of Appeal,

Fourth.Appellate District, Division Three,

concluded that the search of the paper bag

without a search warrant violated the

Fourth Amendment to the United Stites

Constitution. (App. A, B, C, D.)

Petitioner filed a petition for

review arguing that respondent’s Fourth

Amendment rights had not been violated

because the search of the entire car,

including the paper bag, was justified

under United States v. Ross, supra, 456

U.S. 788. The California Supreme Court

denied petitioner’s request for review.

Justice Pannelli dissented, believing that

review should have been granted.

e @ «

STATEMENT OF FACTS

On October 28, 1987, Investigator

Don Coleman of the Santa Ana Police

Department received a telephone call from

United States Drug Enforcement Agent John

McCarthy from Hawaii. Agent McCarthy

informed Investigator Coleman that Agent

McCarthy had seized a package containing a

picnic cooler. Inside the cooler the

agent had found nine clear bags of

marijuana. The bags were approximately

12" by 4" by 3" and each contained about

two pounds of marijuana. The package was

addressed to a J.R. Daza at 805 West

Stevens Avenue, Santa Ana, “alifornia.

The package was to have been sent to the

Federal Express Office at 700 East Alton

in Santa Ana. McCarthy told Coleman that

instead the agent would send the package

to Coleman. The intent of the officers

was to arrest the person who picked up the

marijuana. (CT 64, 71; RT 20.)

a A et

e 9. «

McCarthy sent the package to Coleman

who received it on October 29, 1988.

Coleman opened the package and found the

marijuana in the manner Agent McCarthy had

described. Investigator Coleman

repackaged the box. He then contacted

Mike Cole, the senior operations manager

at the Federal Express Office. Coleman

told Cole that Coleman wanted to leave the

package at Federal Express and then arrest

the person who picked it up. Cole took

the package and kept it under lock. (CT

64, 71; RT 20.)

The next day, Investigator Coleman

went back to the Federal Express Office.

He examined the package containing

marijuana. The package was still under

lock. It had not been tampered with. The

wrapping was the same. A small mark

Coleman had placed on the package was

still there. (CT 64, 71; RT 20.)

LL A EE Ne

nt ee

ee en

- 10. -

A telephone number, apparently on the

delivery instructions from the shipper,

was checked through the Santa Ana Police

Department facilities and found to belong

to a Jamie R. Daza at 807 West Stevens,

Apartment #12 in Santa Ana. A check of

Daza’s California driver’s license

confirmed this same address. At about

10:30 a.m., a man who identified himself

as Jamie Daza went to the Federal £xpress

Office and picked up the package. Daza

placed the package in his car and drove to

his apartment on West Stevens. He carried

the package into the apartment. (CT 64,

71; RT 20.)

Around 11:45 a.m., surveilling

officers saw Daza exit his apartment and

drop the paper and box that had contained

the marijuana into a trash bin. (CT 65;

RT 3.) At this time Investigator Coleman

left the scene to get a search warrant.

(CT 65; RT 3.)

- ll. -

Around 12:10 p.m., co-defendant

St. George was seen by officers exiting

the residence wearing a blue knapsack.

The knapsack appeared to be half full.

Fearing the loss of evidence, the officers

stopped and detained him after he had left

the apartment as he tried to drive out of

the complex. The knapsack was searched

and one and one-half pounds of marijuana

was found. (RT 4; CT 65.)

Around 12:30 p.m., respondent arrived

at the scene. He walked to apartment 12

and entered. Respondent had nothing in

his hands. He exited about ten minutes

later carrying a brown lunch bag that

appeared to be full and about the

appropriate size of the wrapped marijuana

packages that Agent McCarthy had seen.

Respondent was then cbserved to leave the

apartment and walk to a silver Honda in

the parking lot. He placed the brown

lunch bag in the trunk of the Honda and

- 12. -

then attempted to leave. In order to

prevent the possible loss of evidence from

the apartment under surveillance,

respondent’s car was stopped by a marked

police car. The trunk was opened, as was

the bag, and inside the brown bag the

officers found one-quarter to one-half

pound of marijuana. (CT 65.)

The search warrant issued at 12:40

p.m. (See People’s Exh. A at the

suppression hearing.) Shortly thereafter,

Investigator Coleman returned with the

search warrant. The apartment was

searched and numerous bags of marijuana

were found. (CT 71, 74.)

THE SEARCH OF THE PAPER LUNCH

BAG IN THE TRUNK OF THE VEHICLE

WAS JUSTIFIED UNDER THE

AUTOMOBILE EXCEPTION TO THE

FOURTH AMENDMENT WARRANT

REQUIREMENT

The California Court of Appeal held

that the officers illegally searched the

paper lunch bag found in the trunk of the

car, holding that the search fell within

the dictates of Arkansas v. Sanders, 442

U.S. 753, (1979), and United States v.

Chadwick, 433 U.S. 1, (1977), rather than

those of United States v. Ross, 456 U.S.

798, (1982). The pertinent part of the

ruling is summarized by the following

quotation:

"If the officer has probable

cause to believe there is

contraband somewhere in the car,

but he does not know exactly

where, he may search the entire

car as well as any containers

found therein. [Citations. ]

If, on the other hand; the

officer only has probable cause

to believe there is contraband

in a specific container in the

- 14. -

car, he must detain the

container and delay his search

until a search warrant is

obtained. [(Citations]’" (People

v. Acevedo, 216 Cal.App.3d 586,

591-592 (1989), quoting from

Castleberry v. State, 678 P.2d

720, 724, (Okla.Crim.App.

(1984).)

The Court of Appeal then went on to

hold that since the officers had

particularized probable cause to believe

that there was contraband in a particular

location, in this case the paper lunch

bag, rather than generalized probable

cause that there was contraband somewhere

in the vehicle, the officers were required

to obtain a search warrant before opening

the closed paper lunch bag. (People v.

2. The decision of the Oklahoma

court was taken to this Court in

Oklahoma v. Castleberry, 471 U.S. 146,

(1985). This Court granted certiorari

but Justice Powell disqualified himself

from the case. After oral argument the

remaining eight justices deadlocked on

the question presented. This case

presents the exact question that the

Court could not resolve in Castleberry.

eal

- 15. -

Acevedo, supra, 216 Cal.App.3d at pp. 592-

593.)

Respondent contends that the ruling

of the Cou-t of Appeal is at odds with the

holding of this Court in United States v.

Ross, supra. In Ross, this Court

specifically held that once probable cause

exists to believe that a vehicle contains

contraband the entire vehicle may be

searched without a warrant and the “scope

of a warrantless search based on probable

cause is no narrower--and no broader--than

the scope of a search authorized by a

warrant supported by probable cause."

(United States v. Ross, supra, 456 U.S. at

p- 823.)

Respondent submits that the holding

of the Court of Appeal conflicts not only

with Ross, but also with Fourth Amendment

law with regard to the automobile

exception to the general rule requiring a

search warrant. (Cf. Colorado v.

“eR oe _ 8 ee eee OO eee

- 16. -

Bannister, 449 U.S. 1, (1980); Texas v.

White, 423 U.S. 67, (1975); Chambers v.

Maroney, 399 U.S. 42, (1970); Carroll v.

United States, 267 U.S. 132, (1925).)

The clear holding in Ross is that if

“probable cause justifies the search of a

lawfully stopped vehicle, it justified the

search of every part of the vehicle and

its contents that may conceal the object

of the search." (United States v. Ross,

supra, 456 U.S. at p. 825.) Ross stems

from this Court’s earlier automobile

exception cases. Those cases recognized

that the unique mobility of a motor

vehicle gave rise to exigent circumstances

justifying a search without a warrant.

(Carroll v. United States, supra, 267 U.S.

132 at pp. 151-154; United States v. Ross,

supra, at pp. 818-820.) What the Court of

Appeal failed to recognize in the case at

bar is once the bag was placed in the

automobile, it acquired the same degree of

2 me. Om me

- 17. -

mobility as the vehicle itself.

Respondent’s independent and intentional

action of placing the bag in the car

showed an intent to move the bag from its

original location. His driving of the car

was the precise mobility that justified

the searches in Ross and Carroll. Given

such a clear demonstration of mobility,

the exigent circumstances of mobility

encompassed the bag itself and no search

warrant was 1 ,uired.

"The rationale justifying a

warrantless search of an

automobile that is believed to

be transporting contraband

arguably applies with equal

force to any movable container

that is believed to be carrying

an illicit substance." (United

States v. Ross, supra, 456 U.S.

at p. 809.)

Moreover, the holding in the case at

bar is premised on the privacy expectation

that attaches to a closed container.

(People v. Acevedo, supra, 216 Cal.App.3d

at p. 590, citing to United States v.

Chadwick, supra, 433 U.S. 1.) But this

- 18. -

Court has already rejected the concept

that such an expectation of privacy

standard has greater sway than the earlier

inherent mobility-exigent circumstances

standard. In California v. Carney, 471

U.S. 386, 393, (1985), this Court rejected

a claim that the expectation of privacy

surrounding the residency aspects of a

motor home superseded the exigencies

created by the mobility of the motor home.

The potential mobility of the motor home

was dispositive. (Id. at p. 393.) Since

the mobility factor is paramount, it

should have been similarly dispositive in

the case at bar and fully justified the

search of the paper lunch bag.

It is not rational to make the

distinction between whether a search

warrant should be obtained based upon

whether or not the officers had sufficient

knowledge that the contraband was in a

specific container in a specific part of

- 19. -

the vehicle as opposed to being in the

vehicle generally. As Professor LaFave

has noted, such a holding would mean that

police officers may actually be able to

broaden their power to make warrantless

searches by limiting their accumulation of

probable cause. (LaFave, Search and

Seizure, Second Edition, Section 7.2(d),

page 58 (1987).) Indeed, even the

California Court of Appeal recognized the

“anomalous nature of the Ross-Chadwick

dichotomy. . . ." The court noted that it

was creating an “incentive for police

officers to withhold evidence related to

probable cause in order to fit within the

more generous confines of Ross." (People

v. Acevedo, supra, 216 Cal.App.3d at p.

592.) The purpose of the exclusionary

rule is to encourage future police

conformance with the dictates of the

Fourth Amendment, not to reward them for

creative avoidance. Yet the holding in

- 20. - :

the case at bar is admittedly at odds with

the goal of encouraging compliance with

the letter and spirit of the Fourth

Amendment .

Such a rule not only flies in the

face of logic but is also clearly contrary

to the stated desire of this Court to

formulate straightforward, workable rules

regarding the searches of vehicles to

allow the police to make proper decisions

regarding the search of vehicles. (United

States v. Belton, 453 U.S. 454, 458,

(1981).) This Court has held that a

"“*single, familiar standard is essential

to guide police officers, who have only

limited time and expertise to reflect on

and balance the social and individual

interests involved in the specific

circumstances they confront.’ (United

States v. Belton, supra, at p. 458,

quoting Dunaway v. New York, 442 U.S. 200,

213-214, (1979).) The need for

- 21. -

straightforward and predictable rules is

in the interest of both the police and the

citizens who may be subjected to police

activity. (United States v. Belton,

supra, 453 U.S. at pp. 459-460.)

The rule formulated in Ross is clear,

logical and should be applied to the

situation in the case at bar. A rule

requiring a warrant when there is

particularized probable cause will furthcr

cloud what this Court described in Ross as

“this troubled area." (United States v.

Ross, supra, 456 U.S. at p. 817.) Instead

of the straightforward rule of Ross which

looks to the overall existence of probable

cause to search the vehicle and its

contents, endless litigation over whether

the officer knew of the location and

container of the contraband will be

inevitable. A far more workable rule is

the holding in Ross that if “probable

cause justifies the search of a lawfully

- 22. -

stopped vehicle, it justified the search

of every part of the vehicle and its

contents that may conceal the object of

the search." (United States v. Ross,

supra, 456 U.S. at p. 825.) Such a rule

establishes the type of “bright line” this

Court has sought to assist peace officers

in their difficult tasks.» Thus, this

Court’s earlier decision in United States

v. Chadwick, supra, 433 U.S. 1, should be

held to have been overruled by Ross in

situations such as the one in the case at

bar.

Moreover, the holding in the case at

bar creates severe difficulties for peace

officers in the performance of their

duties. In a situation where officers

have sufficient justification to stop a

3. Of course, the fact that at the

actual moment of the search the car and

hence the bag were immobile is

irrelevant since it is the potential for

mobility that controls. (Michigan v.

Thomas, 458 U.S. <59, 261, (1982); per

curiam. )

- 23. -

car for transporting narcotics in a

particular container within a vehicle,

what are the officers to do with the

citizens while they go through the often

lengthy and laborious task of obtaining a

warrant? The probable cause needed for

arrest is inside the bag and the bag

cannot be legally opened. The officer

right detain the citizens but a detention

of such length at some point becomes an

arrest. (Florida v. Royer, 460 U.S. 491,

501-502, (1983).) Thus while the officers

are trying to obtain 4 warrant they may

run the very real risk of inadvertently

arresting a citizen before the contraband

is found. Thus, compliance with the rule

espoused by the Court of Appeal in this

case may result in the officers making

arrests. A far better rule would be to

hold that such containers come with the

holding in Ross. Thus officers could

quickly resolve the situation, promptly

Ee

- 24. -

arresting criminals while speedily

allowing law abiding citizens to proceed

on their way. The rule created by the

Court of Appeal will ensnare officers and

citizens in time consuming and unnecessary

waits to procure warrants.

Since the facts of this case revea]

there was probable cause to believe

respondent’s car contained contraband, the

rationale of United States v. Ross, supra,

should apply. When the closed container

was placed into the car by the respondent,

it became as moveable as the car and thus

the exigent circumstances covering the car

applied to the paper lunch bag as well.

Thus, the Court of Appeal erred in failing

to uphold the search of the paper lunch

bag without a warrant.

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