Coolidge v. New Hampshire
|Coolidge v. New Hampshire|
|Argued January 12, 1971
Decided June 21, 1971
|Full case name||Coolidge v. New Hampshire|
|Citations||403 U.S. 443 (more)|
|Prior history||Certiorari to the Supreme Court of New Hampshire|
|The warrant for the search and seizure of petitioner's automobile did not satisfy the requirements of the Fourth Amendment, because it was not issued by a "neutral and detached magistrate."|
|Majority||Stewart, joined by Burger, Harlan, Douglas, Brennan, Marshall|
|Concur/dissent||Black, joined by Burger, Blackmun|
|Concur/dissent||White, joined by Burger|
The state sought to justify the search of a car owned by Edward Coolidge, suspected of killing 14-year-old Pamela Mason in January 1964, on three theories: automobile exception, search incident, and plain view.
Pamela Mason of Manchester, New Hampshire placed an ad in the window of a local merchant offering to babysit. On January 13, 1964, she was picked up by the person who had called her saying they needed a babysitter. He picked her up to take her to the alleged babysitting location but she was never seen again. Eight days later, Mason was found stabbed and shot to death in a snowbank near Manchester, New Hampshire. The state Attorney General took charge of police activities relating to the murder. When the police applied for a warrant to search suspect Coolidge's automobile, the Attorney General, acting as a justice of the peace, authorized it. Additionally, local police had taken items from Coolidge's home during the course of an interview with the suspect's wife. Coolidge was found guilty and sentenced to life imprisonment, but released in 1991 on a technicality.
Coolidge was also suspected of killing 18-year-old Sandra Valade on February 1, 1960 due to similarities with Mason's murder, but never convicted. In addition, Coolidge was believed to be involved in the February 3, 1964 death of 47-year-old Rena Paquette, who was found burned in a barn on her property. Paquette had been telling people that Coolidge was responsible for Mason's murder and police suspect she may have been killed to withhold information, but her death, originally ruled a suicide, remains unsolved. When Paquette's 36-year-old son Danny was shot to death in his garage on November 9, 1985, Coolidge was considered a suspect since police believe Danny had information about his mother's death. However, he was never tried in either crime and in 2005, 37-year-old Eric Windhurst, the boyfriend of Danny's stepdaughter Melanie Paquette Cooper, who was 15 at the time of his murder, was arrested and pleaded guilty to first degree murder a year later, claiming Melanie told him Danny had been raping and abusing her, a claim Danny's family denies. Coolidge maintains his innocence in Mason's murder and the other murders he was suspected in.
Supreme Court decision
In a decision in which a number of justices chose to concur in part and dissent in part, the Court held that the searches and seizures of Coolidge's property were unconstitutional. Justice Stewart's opinion held that the warrant authorizing the seizure of Coolidge's automobile was invalid because it was not issued by a "neutral and detached magistrate." Stewart also rejected New Hampshire's arguments in favor of making an exception to the warrant requirement. Stewart held that neither the "incident to arrest" doctrine nor the "plain view" doctrine justified the search, and that an "automobile exception" was inapplicable. The court noted that although the "automobile exception" exists, "the word 'automobile' is not a talisman in whose presence the fourth amendment fades away and disappears...".
- Wright, Charles Alan (1971), "Must the Criminal Go Free If the Constable Blunders", Texas Law Review, 50 (4): 736–745.