In U.S. v. Bennett, No. 08-12352 (Jan. 21, 2009), the Court held that no Fourth Amendment violation occurred when police searched under a mattress at a suspect’s mother apartment.
The Court noted that, in the circumstances – e.g., Bennett had delivered a rent check to the landlord – the police reasonably believed that Bennett resided in his mother’s apartment.
Though recognizing it was a close question, the Court concluded that the police search under the mattress was not an unreasonable of the "grab area" of a suspect. Two teenagers were in the room, and police reasonably suspected that they were potentially dangerous because one might have been Bennett, a person known to be dangerous. The police had ordered the two teenagers, handcuffed, to sit on the bed in order to question them. Before questioning, the police shook the sheets and lifted the mattress in order to secure the area. "Although it may have been difficult to [grab the firearm under the mattress] while handcuffed, it is not impossible that the boys could have reached under the mattress for a weapon." The Court noted that precedent allowed police to reach beneath a mattress. "If there is a reason to search the edge of a mattress by touch, there is reason enough to lift it up."