United States v. Richard Johnson

JERRE S. WILLIAMS, Circuit Judge:

This case involves a warrantless search of a zipper-like briefcase by Postal Inspectors during the detention and interrogation of a mail carrier. The Inspectors found evidence during this search upon which the mail carrier was indicted and convicted of embezzlement of mail. The district court denied the defendant’s motions to suppress this evidence found during the search of the briefcase. We reverse, finding that this was not a valid warrantless search incident to an arrest.

I. Factual Background

Appellant Richard Johnson, a mail carrier at the Harvey,…