Clarence Williams and Arlene Jackson v. United States

Williams and Jackson were jointly tried and each was convicted for concealing illegally imported heroin in violation of 21 U.S.C. § 174 . Both of them appeal, raising the issues: (1) Did the District Court err in denying their motions to suppress the heroin as the product of an illegal search? (2) Did the District Court err in denying their motions for acquittal based upon the insufficiency of the evidence to sustain the jury’s implied finding of possession?

We hold: (1) The search was not illegal because Williams' arrest was not as a matter of law a pretext for the warrantless search and because the rule of Chimel v. California (1969) 395 U.S. 752 , 89 S.Ct. 2034 , 23 L.Ed.2d 685 , does not apply to searches conducted before June 23, 1969, the date of the Chimel decision; (2) the evidence was insufficient to support Jackson’s conviction; and (3) the evidence was sufficient to support Williams’ conviction.

Legality of the Search

Jackson and Williams contend that the heroin was the product of an illegal search because Williams’ arrest was a pretext for a warrantless search of the Granada Street residence in which he was arrested and because the scope of the search went beyond…