Jones v. United States
4 L. Ed. 2d 697 · Supreme Court of the United States · 1960
Facts
Petitioner Jones was arrested in an apartment in the District of Columbia by federal narcotics officers executing a search warrant. Officers discovered narcotics, lacking appropriate stamps, and drug paraphernalia in a bird's nest located in an awning just outside a window of the apartment. Another officer had observed Jones place his hand on the awning shortly before the discovery. Upon the discovery, Jones admitted to the officers that some of the items were his and that he was living in the apartment. The apartment belonged to a friend, Evans, who had given Jones permission to use it and provided him with a key. Jones had a suit and shirt at the apartment, had slept there "maybe a night," and paid nothing for its use, while Evans was away.
Procedural history
Petitioner was found guilty on both counts in the District Court and sentenced to seven years. The District Court denied his motion to suppress evidence solely due to lack of standing. The Court of Appeals affirmed the conviction, agreeing with the District Court on standing but also ruling the evidence was lawfully received even if standing existed. The Supreme Court granted certiorari to address standing and the legality of the search.
Issue
Did the petitioner have standing to challenge the legality of the search of the apartment, given he was an invitee and charged with possession of the seized narcotics? Was the search warrant issued with probable cause, considering the affidavit relied on hearsay from an unnamed informant?
Holding
The Court held that the petitioner had standing to challenge the search. It also held that the affidavit provided sufficient probable cause for the search warrant. The case was vacated and remanded for the District Court to consider the legality of the warrant's execution.
Rule
The Court established two grounds for standing: (1) When possession of the seized evidence is itself an essential element of the offense charged, the defendant is automatically deemed to have standing to challenge the search. This prevents the government from taking contradictory positions. (2) Anyone legitimately on the premises at the time of a search has standing to challenge its legality, rejecting common law property distinctions like "lessee" or "invitee" as irrelevant to Fourth Amendment protections. For probable cause, an affidavit based on hearsay is sufficient if it provides a substantial basis for crediting the hearsay, such as the informant's past reliability, corroboration by other sources, and the defendant's known history.
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