United States v. Place (1983) 412 US 696

Prolonged Detention

When defendant arrived at the airport on a Friday afternoon, he was met by drug enforcement agents. When defendant refused to consent to a search of his bags, an agent told him that they were going to take the bags to a federal judge to obtain a search warrant. The agents transported the bags to another airport to subject them to a sniff test by a narcotics detection dog that reacted positively to one of the bags. Ninety minutes had elapsed since the seizure of the bags. The agents retained the bags until Monday morning when they secured a search warrant for the bag wherein they discovered cocaine. The Court affirmed the reversal of defendant’s conviction on the basis that the evidence obtained from the search was inadmissible. The 90-minute detention of respondent’s luggage went beyond the narrow authority possessed by police to detain briefly luggage reasonably suspected to contain narcotics. The violation was exacerbated by the agents’ failure to accurately inform the defendant where they were transporting his bags, how long he might be dispossessed, and what arrangements would be made for return of the bags if the investigation dispelled the suspicion.