Berkemer v. McCarty, 468 U.S. 420 (1984)

Facts

McCarty was seen weaving in and out of a lane and was stopped.  McCarty was asked to step out of the car and a field sobriety test was performed.  McCarty was also asked if he had been using intoxicants and McCarty responded he had.  McCarty was taken to the police station and asked again about the beer and marijuana he consumed.  McCarty was never given Miranda warnings.

Procedural History

McCarty moved to suppress the various statements he made and the trial court denied the motion.

Issue(s)

Did the trial court err in not suppressing McCarty’s statements because he had not been given the Miranda warnings?

Holding(s)

No.

Reasoning/Analysis

The Court found that a person subjected to custodial interrogation is entitled to Miranda warnings regardless of the severity of the offense.  However, we refuse to adopt McCarty’s argument every detained motorist must be advised of his rights.  Questioning at a traffic stop is different from stationhouse interrogation and is more analogous to a Terry stop.  Nothing in the record indicates McCarty should have been given Miranda warnings prior to being placed under arrest.

Judgment/Outcome

The Court affirmed the judgment of the trial court.

Arizona v. Roberson, 486 U.S. 675 (1988)

Facts

Roberson was arrested at the scene of a burglary and advised of his Miranda rights.  Roberson replied he wanted a lawyer and this was duly noted.  Three days later, while Roberson was still in custody, a different officer interrogated Roberson about a different burglary.

Procedural History

Roberson moved to suppress his statements and the trial court granted the suppression.

Issue(s)

Did the trial court err in suppressing Roberson’s statements when he previously invoked his right to remain silent and was later interrogated on a different crime?

Holding(s)

No.

Reasoning/Analysis

The Court found that in Edwards, we concluded that reinterrogation may only occur if the accused himself indicates further communication, exchanges, or conversations with the police.  Arizona’s attempt to create an exception to Edwards where there is a separate investigation is unavailing. 

Judgment/Outcome

The Court affirmed the judgment of the Arizona Court of Appeals.

Aguilar v. Texas, 378 U.S. 108 (1964)

Facts

Two Houston officers applied for a search warrant based on an affidavit stating they had received reliable information from a credible person that Aguilar possessed narcotics for sale.  The search warrant was issued and upon searching the house, the officers did discover narcotics.

Procedural History

Aguilar objected to the introduction of the evidence but the objections were overruled and the evidence admitted.  Aguilar was convicted.  The Court of Appeals affirmed. 

Issue(s)

Did the trial court err in not excluding the evidence obtained from the search of Aguilar’s home?

Holding(s)

Yes.

Reasoning/Analysis

The Court found that so long as there was a substantial basis for the magistrate to issue the warrant, courts will accept evidence of a less judicially competent or persuasive character than would have justified an officer.  The affidavit relied upon by the magistrate contained no allegation that either the affiant or the source spoke with personal knowledge.  The magistrate must be informed of some of the underlying circumstances.

 Judgment/Outcome

 The Court reversed the judgment of the lower courts.

Concurring Opinions/Dissenting Opinions/Comments

Clark dissented stating that the totality of the circumstances upon which the officer relied is certainly pertinent to the validity of the warrant.

Connecticut v. Barrett, 479 U.S. 523 (1987)

Facts

Barrett had been arrested for sexual assault.  Barrett was given his Miranda rights and said he would not give a written statement without his attorney but had no problem talking about the incident.  The tape recorder failed twice so officers transcribed what they had been told by Barrett.

Procedural History

Barrett moved to suppress but the trial court held the confession was admissible.  The Connecticut Supreme Court reversed, finding that Barrett had invoked his right to counsel.

Issue(s)

Did the Connecticut Supreme Court err in finding that Barrett had invoked his right to counsel by refusing to make a written statement without his attorney?

Holding(s)

Yes.

Reasoning/Analysis

The Court found that interpretation is only required where the defendant’s words, understood as ordinary people would understand them, are ambiguous.  Here, however, Barrett made clear his intentions, and they were honored by police.

Judgment/Outcome

The Court reversed and remanded the judgment of the Connecticut Supreme Court.

Colorado v. Connelly, 479 U.S. 157 (1986)

Facts

Anderson was working off-duty when he was approached by Connelly, who confessed to a murder.  Connelly was advised of his rights but he insisted on talking.  Connelly was taken to the station, where records showed an unidentified murder was discovered 6 months after Connelly’s supposed murder.  Connelly was held overnight and after being evaluated, it was determined he suffered from chronic schizophrenia.

Procedural History

Connelly moved to suppress his statements and the trial court granted the suppression, finding that the statements were involuntary.  The Colorado Supreme Court affirmed, finding that the absence of police coercion does not foreclose a finding of involuntariness.

Issue(s)

Did the Colorado Supreme Court err in finding that even without police coercion, a statement can be deemed involuntary via the Due Process Clause?

Holding(s)

Yes.

Reasoning/Analysis

The Court found that absent police conduct causally related to the confession, there is simply no basis for concluding that any state actor has deprived a criminal defendant of due process of law.  A defendant’s mental condition, by itself and apart from its relation to official coercion, should never dispose of the inquiry into constitutional voluntariness.  The Supreme Court of Colorado also erred in importing into this are of constitutional law notions of free will that have no place there.

Judgment/Outcome

The Court reversed the judgment of the Colorado Supreme Court.

Chimel v. California, 395 U.S. 752 (1969)

Facts

Officers arrived at the home of Chimel with a warrant for his arrest for the burglary of a coin shop.  The officers asked Chimel for permission to look around.  Chimel objected but was advised they would nonetheless conduct the search.  No search warrant was issued.  The officers seized numerous items, primarily coins.

Procedural History

The items taken from Chimel’s home were admitted at trial and Chimel was convicted.  His conviction was affirmed by the Court of Appeals and the California Supreme Court.

Issue(s)

Was the warrantless search of Chimel’s home constitutionally justified as incident to his arrest?

Holding(s)

No.

Reasoning/Analysis

The Court found that when an arrest is made, it is reasonable to search the person arrested and the area into which the arrestee might grab to remove any weapons.  There is no comparable justification for routinely searching any room other than that in which the arrest occurs.  The search here went far beyond the petitioner’s person and the area from which he might have obtained either a weapon or something that could have been used as evidence against him.

Judgment/Outcome

The Court reversed the judgment of the lower courts.

California v. Greenwood, 486 U.S. 35 (1988)

Facts

Investigators had received tips that Greenwood was selling narcotics from his home and Stracner personally observed several vehicles make brief stops at the home.  Stracner requested that Greenwood’s trash be set aside from other trash and given to her.  Items indicative of narcotics use was found.  Based on this information, a warrant was issued and cocaine and hashish were discovered during the search.  Greenwood posted bail and the same activity occurred again.

Procedural History

 

Issue(s)

Does the Fourth Amendment prohibit the warrantless search and seizure of garbage left for collection outside the curtilage of the home?

Holding(s)

No.

Reasoning/Analysis

The court found that Greenwood exposed his garbage to the public sufficiently to defeat his claim to Fourth Amendment protection.  It is common knowledge that plastic garbage bags left at the side of a public street are readily accessible to animals, children, scavengers, snoops, and other members of the public.

Judgment/Outcome

The Court reversed the judgment of the California Court of Appeals.

California v. Ciraolo, 476 U.S. 207 (1986)

Facts

Santa Clara police received an anonymous tip that marijuana was growing in Ciraolo’s backyard.  Police could not observe the backyard from ground level and flew a plane over his backyard at 1,000 feet, taking pictures with a 35mm camera.  With this, a search warrant was issued and 73 plants were seized.

Procedural History

Ciraolo filed a motion to suppress, which was denied.  After this denial, Ciraolo pled guilty.  The California Court of Appeals reversed, finding the aerial observation violated the Fourth Amendment.

Issue(s)

Was the aerial observation of Ciraolo’s backyard a violation of his Fourth Amendment right to privacy and thus issuance of the warrant was improper?

Holding(s)

No.

Reasoning/Analysis

The Court found that the test of legitimacy is not whether the individual chooses to conceal private activity, but whether the intrusion infringes upon personal and societal values protected by the Fourth Amendment.  That the area is within the curtilage does not bar all police observation.  The observations occurred in public navigable airspace in a physically nonintrusive manner which could have been observed by the flying public.

Judgment/Outcome

The Court reversed the judgment of the California Court of Appeals.

Bumper v. North Carolina, 391 U.S. 543 (1968)

Facts

Bumper lived with his grandmother and was accused of rape.  Police arrived at the grandmother’s home and announced they had a search warrant, but they had none.  The grandmother responded, “Go ahead.”  The officers discovered a rifle allegedly used in the crime.

Procedural History

The trial court denied Bumper’s motion to suppress the rifle, finding that the grandmother had given her consent for the search.  The Supreme Court of North Carolina affirmed.

Issue(s)

Did the trial court err in finding that the grandmother voluntarily consented to the search of her home, thus making the evidence of the rifle allowable?

Holding(s)

Yes.

Reasoning/Analysis

The Court found that when a law enforcement officer claims authority to search a home under a warrant, he announces in effect that the occupant has no right to resist the search.  The situation is instinct with coercion.  The grandmother did not consent to the search and admission of the rifle was in error.

Judgment/Outcome

The Court reversed the judgment of the Supreme Court of North Carolina.

Brown v. Illinois, 422 U.S. 590 (1975)

Facts

Corpus was murdered and Brown’s name was one provided.  Officers went to Brown’s apartment, waited for him to arrive, and arrested him.  The police did not have probable cause or a warrant for the arrest.  While in custody, Brown was informed of his rights under Miranda.  Questioning of Brown came to two admissions that he and Claggett were involved in the murder of Corpus.

Procedural History

Brown moved to suppress the two statements he had made, claiming that the arrest was illegal and thus the statements were in violation of his constitutional rights.  The motion was denied and Brown was convicted.  The Illinois Supreme Court affirmed, finding that although the arrest was illegal, the statements were an act of free will.

Issue(s)

Did the Illinois Supreme Court err in finding that the statements made by Brown, although after an illegal arrest, were properly admitted by the trial court.

Holding(s)

Yes.

Reasoning/Analysis

The Court found that Miranda warnings, alone and per se, cannot always make the act sufficiently a product of free will; they cannot assure in every case that the Fourth Amendment violation has not been unduly exploited.  We therefore reject the per se rule articulated by the Illinois Supreme Court and also decline to adopt any alternative per se rule.

Judgment/Outcome

The Court reversed and remanded the judgment of the Illinois Supreme Court.