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appealrespondent

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Florida v. Royer

Facts

On January 3, 1978, Royer was observed at Miami International Airport by two detectives who believed he fit the profile of a drug courier. After purchasing a one-way ticket to New York and checking his luggage, the detectives approached him, identified themselves, and asked to see his identification. When discrepancies arose between the name on his airline ticket and his driver's license, the detectives asked him to accompany them to a small room, where they subsequently searched his luggage without a warrant or probable cause.

On January 3, 1978, Royer was observed at Miami International Airport by two plainclothes detectives of the Dade County, Fla., Public Safety Department assigned to the county's Organized Crime Bureau, Narcotics Investigation Section. Detectives Johnson and Magdalena believed that Royer's appearance, mannerisms, luggage, and actions fit the so-called 'drug courier profile.'

Issue

Whether the Court of Appeal of Florida properly applied the Fourth Amendment in holding that Royer was being illegally detained at the time of his purported consent to a search of his luggage.

We are required in this case to determine whether the Court of Appeal of Florida, Third District, properly applied the precepts of the Fourth Amendment in holding that respondent Royer was being illegally detained at the time of his purported consent to a search of his luggage.

Rule

The validity of a search depends on the consent being freely and voluntarily given, and a police confinement that exceeds the limited restraint of an investigatory stop requires probable cause.

It is unquestioned that without a warrant to search Royer's luggage and in the absence of probable cause and exigent circumstances, the validity of the search depended on Royer's purported consent.

Analysis

The Court found that Royer's consent to the search was involuntary because he was effectively seized at the time he consented. The detectives' actions, including retaining his identification and asking him to accompany them to a small room, constituted an unlawful detention that tainted his consent. The absence of probable cause at the time of the search rendered the consent ineffective.

In the absence of probable cause, the court concluded, Royer's consent to search, given only after he had been unlawfully confined, was ineffective to justify the search.

Conclusion

The Court affirmed the judgment of the court of appeal, concluding that Royer's consent was invalid due to his illegal detention, and thus the search of his luggage was unconstitutional.

We granted the State's petition for certiorari, 454 U.S. 1079 (1981), and now affirm.

Who won?

Royer prevailed in the case because the Supreme Court upheld the appellate court's ruling that his consent to search was invalid due to illegal detention.

Royer had 'found himself in a small enclosed area being confronted by two police officers — a situation which presents an almost classic definition of imprisonment.'

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