Facts
Wilson made a series of narcotics sales to police informant. The police applied for, and were granted, a search and arrest warrant. Officers arrived, finding the main door open but the screen door closed. Officers entered, then identified themselves and that they had a warrant.
Procedural History
Wilson moved to suppress the evidence seized from the search and the trial court denied the motion. The Arkansas Supreme court affirmed.
Issue(s)
Did the Arkansas Supreme Court err in finding that the knock and announce principle is not required by the Fourth Amendment?
Holding(s)
Yes.
Reasoning/Analysis
The Court found that the knock and announce principle is deeply rooted in the common law and given the longstanding common-law endorsement, we have little doubt that the Framers of the Fourth Amendment thought that the method of an officer’s entry into a dwelling was among the factors to be considered in assessing the reasonableness of a search or seizure.
Judgment/Outcome
The Court reversed and remanded the judgment of the Arkansas Supreme Court.
Showing posts with label Criminal Procedure. Show all posts
Showing posts with label Criminal Procedure. Show all posts
Sunday, May 17, 2009
Warden v. Hayden, 387 U.S. 294 (1967)
Facts
Armed robber entered cab company and stole $363. Two cab drivers followed the man to his address and called the police. Mrs. Hayden answered and officers asked if they could search the house; she consented. Hayden was found upstairs and guns and ammunition were found in other rooms upstairs.
Procedural History
The Court of Appeals found that neither the entry without a warrant nor the search for Hayden without a warrant was invalid.
Issue(s)
Did the Court of Appeals err?
Holding(s)
No.
Reasoning/Analysis
The Court found that the Fourth Amendment does not require police officers to delay in the course of an investigation if to do so would gravely endanger their lives or the lives of others. The officers were justified in searching for weapons because they knew the robber was armed.
Judgment/Outcome
The Court affirmed the judgment of the Court of Appeals.
Armed robber entered cab company and stole $363. Two cab drivers followed the man to his address and called the police. Mrs. Hayden answered and officers asked if they could search the house; she consented. Hayden was found upstairs and guns and ammunition were found in other rooms upstairs.
Procedural History
The Court of Appeals found that neither the entry without a warrant nor the search for Hayden without a warrant was invalid.
Issue(s)
Did the Court of Appeals err?
Holding(s)
No.
Reasoning/Analysis
The Court found that the Fourth Amendment does not require police officers to delay in the course of an investigation if to do so would gravely endanger their lives or the lives of others. The officers were justified in searching for weapons because they knew the robber was armed.
Judgment/Outcome
The Court affirmed the judgment of the Court of Appeals.
Wade v. United States, 388 U.S. 218 (1967)
Facts
A federal bank was robbed when a teller and vice president were the only people present. Wade was indicted and arrested for the robbery then had counsel appointed. An FBI agent conducted a lineup without notice to Wade’s counsel. Both employees identified Wade.
Procedural History
The employees identified Wade in the courtroom and the lineup was elicited. Wade moved for acquittal or to strike the courtroom identification. The trial court denied the motion.
Issue(s)
Did the trial court err in not striking the courtroom identification when the previous lineup was conducted outside the presence of Wade’s counsel?
Holding(s)
Yes.
Reasoning/Analysis
The Court found that there is nothing to show the lineup violated Wade’s Fifth Amendment privilege against self-incrimination but the lineup should have been excluded because it was conducted without notice to and in the absence of his counsel. The Sixth Amendment guarantee applies to “critical” stages of the proceedings. The accused’s inability effectively to reconstruct at trial any unfairness that occurred at the lineup may deprive him of his only opportunity meaningfully to attack the credibility of the witness’ courtroom identification. There can be little doubt that the post-indictment lineup was a critical stage of the prosecution. The proper test to be applied is that from Wong Sun.
Judgment/Outcome
The Court reversed and remanded the judgment of the lower courts.
A federal bank was robbed when a teller and vice president were the only people present. Wade was indicted and arrested for the robbery then had counsel appointed. An FBI agent conducted a lineup without notice to Wade’s counsel. Both employees identified Wade.
Procedural History
The employees identified Wade in the courtroom and the lineup was elicited. Wade moved for acquittal or to strike the courtroom identification. The trial court denied the motion.
Issue(s)
Did the trial court err in not striking the courtroom identification when the previous lineup was conducted outside the presence of Wade’s counsel?
Holding(s)
Yes.
Reasoning/Analysis
The Court found that there is nothing to show the lineup violated Wade’s Fifth Amendment privilege against self-incrimination but the lineup should have been excluded because it was conducted without notice to and in the absence of his counsel. The Sixth Amendment guarantee applies to “critical” stages of the proceedings. The accused’s inability effectively to reconstruct at trial any unfairness that occurred at the lineup may deprive him of his only opportunity meaningfully to attack the credibility of the witness’ courtroom identification. There can be little doubt that the post-indictment lineup was a critical stage of the prosecution. The proper test to be applied is that from Wong Sun.
Judgment/Outcome
The Court reversed and remanded the judgment of the lower courts.
Veronia School District 47J v. Acton, 515 U.S. 646 (1995)
Facts
Veronia School District began to see problems with drug use in its schools and felt that athletes were among the largest users. After a parent meeting, the District implemented a drug testing policy for all student athletes, which required a test at the beginning of the season and random tests throughout the season. Acton and his parents refused to sign the testing consent forms.
Procedural History
The Actons filed for a declaratory judgment and an injunction, but the District Court denied the claims. The Ninth Circuit reversed, finding the District’s policy violated the Fourth and Fourteenth Amendments.
Issue(s)
Did the Ninth Circuit err in finding that a school district’s policy of drug testing student athletes is a violation of the Fourth Amendment?
Holding(s)
Yes.
Reasoning/Analysis
The Court found that a search unsupported by probable cause can be constitutional when special needs make the warrant and probable cause requirements impractical. These special needs have been found to exist in the public-school context. Fourth Amendment rights are different in public schools; the reasonableness inquiry cannot disregard the school’s custodial and tutelary responsibility for children. Legitimate privacy expectations are even less with regard to student athletes. When looking at all of the factors – decreased expectation of privacy, relative unobtrusiveness of the search, and the severity of the need met by the search – we conclude Veronia’s policy is reasonable and hence constitutional.
Judgment/Outcome
The Court reversed and remanded the judgment of the Ninth Circuit.
Veronia School District began to see problems with drug use in its schools and felt that athletes were among the largest users. After a parent meeting, the District implemented a drug testing policy for all student athletes, which required a test at the beginning of the season and random tests throughout the season. Acton and his parents refused to sign the testing consent forms.
Procedural History
The Actons filed for a declaratory judgment and an injunction, but the District Court denied the claims. The Ninth Circuit reversed, finding the District’s policy violated the Fourth and Fourteenth Amendments.
Issue(s)
Did the Ninth Circuit err in finding that a school district’s policy of drug testing student athletes is a violation of the Fourth Amendment?
Holding(s)
Yes.
Reasoning/Analysis
The Court found that a search unsupported by probable cause can be constitutional when special needs make the warrant and probable cause requirements impractical. These special needs have been found to exist in the public-school context. Fourth Amendment rights are different in public schools; the reasonableness inquiry cannot disregard the school’s custodial and tutelary responsibility for children. Legitimate privacy expectations are even less with regard to student athletes. When looking at all of the factors – decreased expectation of privacy, relative unobtrusiveness of the search, and the severity of the need met by the search – we conclude Veronia’s policy is reasonable and hence constitutional.
Judgment/Outcome
The Court reversed and remanded the judgment of the Ninth Circuit.
Vale v. Louisiana, 399 U.S. 30 (1970)
Facts
Officers observed a vehicle approach Vale’s home. Vale came out to meet the vehicle, looking around the entire time. Vale returned to his house then went back to the vehicle. Officers assumed a narcotics sale was occurring and went to intervene. Vale returned to his house but was told to stop at his front steps. Officers entered the home based on the witnessed transaction and discovered narcotics in a rear bedroom.
Procedural History
The Louisiana Supreme Court held that the search of the house did not violate the Fourth Amendment because it occurred in the immediate vicinity of the arrest.
Issue(s)
Did the Louisiana Supreme Court err?
Holding(s)
Yes.
Reasoning/Analysis
The Court found that a search may be incident to an arrest only if it substantially contemporaneous with the arrest and is confined to the immediate vicinity of the arrest. The officers here were not responding to an emergency and were not in his pursuit of a fleeing felon. We decline to hold that an arrest on the street can provide its own exigent circumstance so as to justify a warrantless search of the arrestee’s house.
Judgment/Outcome
The Court reversed and remanded the judgment of the Louisiana Supreme Court.
Officers observed a vehicle approach Vale’s home. Vale came out to meet the vehicle, looking around the entire time. Vale returned to his house then went back to the vehicle. Officers assumed a narcotics sale was occurring and went to intervene. Vale returned to his house but was told to stop at his front steps. Officers entered the home based on the witnessed transaction and discovered narcotics in a rear bedroom.
Procedural History
The Louisiana Supreme Court held that the search of the house did not violate the Fourth Amendment because it occurred in the immediate vicinity of the arrest.
Issue(s)
Did the Louisiana Supreme Court err?
Holding(s)
Yes.
Reasoning/Analysis
The Court found that a search may be incident to an arrest only if it substantially contemporaneous with the arrest and is confined to the immediate vicinity of the arrest. The officers here were not responding to an emergency and were not in his pursuit of a fleeing felon. We decline to hold that an arrest on the street can provide its own exigent circumstance so as to justify a warrantless search of the arrestee’s house.
Judgment/Outcome
The Court reversed and remanded the judgment of the Louisiana Supreme Court.
United States v. White, 401 U.S. 745 (1971)
Facts
White and Jackson, an informant, had conversations regarding narcotics transactions. The informant was wearing a radio transmitter so agents could overhear the conversations.
Procedural History
Jackson could not be located for trial and the trial court overruled objections of to the agents’ testimony who conducted the surveillance. White was found guilty by a jury and the Court of Appeals reversed, interpreting the Fourth Amendment to forbid the introduction of the agents’ testimony in the circumstances.
Issue(s)
Does the Fourth Amendment bar testimony of government agents who related conversations overheard from a radio transmitter?
Holding(s)
No.
Reasoning/Analysis
The Court found that based on Hoffa and Lewis, if the law gives no protection to the wrongdoer whose trusted accomplice is or becomes a police agent, neither should it protect him when that same agent has recorded or transmitted the conversations which are later offered in evidence.
Judgment/Outcome
The Court reversed the judgment of the Court of Appeals.
White and Jackson, an informant, had conversations regarding narcotics transactions. The informant was wearing a radio transmitter so agents could overhear the conversations.
Procedural History
Jackson could not be located for trial and the trial court overruled objections of to the agents’ testimony who conducted the surveillance. White was found guilty by a jury and the Court of Appeals reversed, interpreting the Fourth Amendment to forbid the introduction of the agents’ testimony in the circumstances.
Issue(s)
Does the Fourth Amendment bar testimony of government agents who related conversations overheard from a radio transmitter?
Holding(s)
No.
Reasoning/Analysis
The Court found that based on Hoffa and Lewis, if the law gives no protection to the wrongdoer whose trusted accomplice is or becomes a police agent, neither should it protect him when that same agent has recorded or transmitted the conversations which are later offered in evidence.
Judgment/Outcome
The Court reversed the judgment of the Court of Appeals.
United States v. Turner, 926 F.2d 883 (1990)
Facts
It was thought that Turner was selling narcotics and the police employed a paid informant. It was discovered through this informant that Turner kept weapons in the apartment for his drug operation. A search warrant was issued and officers recovered weapons, ammunition, and narcotics equipment. The grand jury subsequently indicted Turner, an arrest warrant was issued, and officers entered an apartment and found Turner with a .45 caliber in the sheets. Turner was arrested and taken to another room. Officers discovered a rifle, ammunition, and baggies of cocaine.
Procedural History
The district court denied Turner’s motion to suppress and Turner was convicted.
Issue(s)
Did the district court err in denying Turner’s motion to suppress when the search occurred after Turner was removed to a different room?
Holding(s)
No.
Reasoning/Analysis
The Court found a two part inquiry best serve’s the issue: (1) whether the search was within the arrestee’s immediate control when he was arrested and (2) whether events occurring after the arrest but before the search made the search unreasonable. The Court found that the baggies of cocaine were within Turner’s control when he was arrested and that the events after the arrest but before the search did not make the search unreasonable. Turner was removed from the room for officer safety.
Judgment/Outcome
The Court affirmed the judgment of the district court.
It was thought that Turner was selling narcotics and the police employed a paid informant. It was discovered through this informant that Turner kept weapons in the apartment for his drug operation. A search warrant was issued and officers recovered weapons, ammunition, and narcotics equipment. The grand jury subsequently indicted Turner, an arrest warrant was issued, and officers entered an apartment and found Turner with a .45 caliber in the sheets. Turner was arrested and taken to another room. Officers discovered a rifle, ammunition, and baggies of cocaine.
Procedural History
The district court denied Turner’s motion to suppress and Turner was convicted.
Issue(s)
Did the district court err in denying Turner’s motion to suppress when the search occurred after Turner was removed to a different room?
Holding(s)
No.
Reasoning/Analysis
The Court found a two part inquiry best serve’s the issue: (1) whether the search was within the arrestee’s immediate control when he was arrested and (2) whether events occurring after the arrest but before the search made the search unreasonable. The Court found that the baggies of cocaine were within Turner’s control when he was arrested and that the events after the arrest but before the search did not make the search unreasonable. Turner was removed from the room for officer safety.
Judgment/Outcome
The Court affirmed the judgment of the district court.
United States v. Sharpe, 470 U.S. 675 (1985)
Facts
Cooke was on patrol when he noticed a suspicious camper and car. Cooke called for assistance, and after following for some distance, they pulled the car over but the camper sped off. The camper was pulled over a ½ mile later. Cooke went to assist with the camper, asked Savage if he could search the camper, and after being told no, smelt marijuana and searched anyways. The camper contained bales of marijuana.
Procedural History
The District Court denied the motion to suppress and the Court of Appeals reversed.
Issue(s)
Did the Court of Appeals err in reversing, finding that the length of the detention was unreasonable and a violation of the Fourth Amendment?
Holding(s)
Yes.
Reasoning/Analysis
The Court found that based on the circumstances surrounding the stop of Savage, the detention clearly met the Fourth Amendment’s standard of reasonableness. In assessing whether a detention is too long, we consider it appropriate to examine whether the police diligently pursued a means of investigation that was likely to confirm or dispel their suspicions quickly, during which time it was necessary to detain the defendant.
Judgment/Outcome
The court reversed the judgment of the Court of Appeals.
Cooke was on patrol when he noticed a suspicious camper and car. Cooke called for assistance, and after following for some distance, they pulled the car over but the camper sped off. The camper was pulled over a ½ mile later. Cooke went to assist with the camper, asked Savage if he could search the camper, and after being told no, smelt marijuana and searched anyways. The camper contained bales of marijuana.
Procedural History
The District Court denied the motion to suppress and the Court of Appeals reversed.
Issue(s)
Did the Court of Appeals err in reversing, finding that the length of the detention was unreasonable and a violation of the Fourth Amendment?
Holding(s)
Yes.
Reasoning/Analysis
The Court found that based on the circumstances surrounding the stop of Savage, the detention clearly met the Fourth Amendment’s standard of reasonableness. In assessing whether a detention is too long, we consider it appropriate to examine whether the police diligently pursued a means of investigation that was likely to confirm or dispel their suspicions quickly, during which time it was necessary to detain the defendant.
Judgment/Outcome
The court reversed the judgment of the Court of Appeals.
United States v. Santana
Facts
Undercover officer was attempting to make a heroin buy from McCafferty. McCafferty drove officer to Santana’s residence, McCafferty went inside, then returned with heroin. McCafferty was placed under arrest and other officers went to Santana’s home, finding her standing in the doorway. As the officers approached, Santana went inside and officers proceeded inside, discovering narcotics and the marked bills from the transaction.
Procedural History
Trial court granted Santana’s motion to suppress and the Court of Appeals affirmed.
Issue(s)
Did the lower courts err in suppressing the evidence retrieved from the search when Santana was noticed standing in the doorway?
Holding(s)
Yes.
Reasoning/Analysis
The Court found that it is clear that Santana was in a public place and not where she had an expectation of privacy. The act of retreating into the house could not thwart an otherwise proper arrest. A suspect may not defeat arrest which has been set in motion in a public place by the expedient of escaping into a private place.
Judgment/Outcome
The Court reversed and remanded the judgment of the lower courts.
Undercover officer was attempting to make a heroin buy from McCafferty. McCafferty drove officer to Santana’s residence, McCafferty went inside, then returned with heroin. McCafferty was placed under arrest and other officers went to Santana’s home, finding her standing in the doorway. As the officers approached, Santana went inside and officers proceeded inside, discovering narcotics and the marked bills from the transaction.
Procedural History
Trial court granted Santana’s motion to suppress and the Court of Appeals affirmed.
Issue(s)
Did the lower courts err in suppressing the evidence retrieved from the search when Santana was noticed standing in the doorway?
Holding(s)
Yes.
Reasoning/Analysis
The Court found that it is clear that Santana was in a public place and not where she had an expectation of privacy. The act of retreating into the house could not thwart an otherwise proper arrest. A suspect may not defeat arrest which has been set in motion in a public place by the expedient of escaping into a private place.
Judgment/Outcome
The Court reversed and remanded the judgment of the lower courts.
United States v. Robinson, 414 U.S. 218 (1973)
Facts
Robinson was stopped by Jenks for operating a motor vehicle after the revocation of his permit. Robinson and the occupants emerged from the vehicle and Jenks informed Robinson he was under arrest. While patting Robinson down, Jenks felt an object in the coat, which he removed and discovered was a crumpled cigarette pack. Jenks then opened the cigarette pack and discovered gelatin capsules of heroin.
Procedural History
The heroin seized from Robinson was admitted as evidence in his trial and Robinson was convicted. The Court of Appeals reversed.
Issue(s)
Was the officer’s search of the crumpled cigarette package, which Jenks admitted he did not know what was inside, a violation of the Fourth Amendment?
Holding(s)
No.
Reasoning/Analysis
The Court found that the Court of Appeals holding that the officer may only conduct a limited frisk, per Terry v. Ohio, was incorrect because Terry does not carry over to a probable cause arrest. The Court also disagreed with the Court of Appeals finding that a stop for driving on a suspended license is less likely to discover weapons than a different stop. The Court found that in the case of a lawful custodial arrest, a full search of the person is not only an exception to the warrant requirement of the Fourth Amendment, but is also a reasonable search under that Amendment.
Judgment/Outcome
The Court reversed the judgment of the Court of Appeals.
Robinson was stopped by Jenks for operating a motor vehicle after the revocation of his permit. Robinson and the occupants emerged from the vehicle and Jenks informed Robinson he was under arrest. While patting Robinson down, Jenks felt an object in the coat, which he removed and discovered was a crumpled cigarette pack. Jenks then opened the cigarette pack and discovered gelatin capsules of heroin.
Procedural History
The heroin seized from Robinson was admitted as evidence in his trial and Robinson was convicted. The Court of Appeals reversed.
Issue(s)
Was the officer’s search of the crumpled cigarette package, which Jenks admitted he did not know what was inside, a violation of the Fourth Amendment?
Holding(s)
No.
Reasoning/Analysis
The Court found that the Court of Appeals holding that the officer may only conduct a limited frisk, per Terry v. Ohio, was incorrect because Terry does not carry over to a probable cause arrest. The Court also disagreed with the Court of Appeals finding that a stop for driving on a suspended license is less likely to discover weapons than a different stop. The Court found that in the case of a lawful custodial arrest, a full search of the person is not only an exception to the warrant requirement of the Fourth Amendment, but is also a reasonable search under that Amendment.
Judgment/Outcome
The Court reversed the judgment of the Court of Appeals.
United States v. Mendenhall, 446 U.S. 544 (1980)
Facts
Mendenhall was walking through Detroit Metropolitan Airport when she was approached by narcotics agents. After some questions, the agents asked if Mendenhall would come to the DEA office, which she did. After entering the office, Mendenhall also allegedly consented to a search, where heroin was found on her.
Procedural History
The District Court denied the motion to suppress, finding that the initial approach of Mendenhall was permissible under Terry. The Court of Appeals reversed, finding that the search was not consented, but a product of earlier official conduct violative of the Fourth Amendment.
Issue(s)
Did the District Court err in finding that the narcotics agents’ initial questioning of Mendenhall was permissible?
Holding(s)
No.
Reasoning/Analysis
The Court found that a person is seized only when, by means of physical force or show of authority, his freedom of movement is restrained. As long as the person to whom questions are put remains free to disregard the questions and walk away, there has been no intrusion upon that person’s liberty or privacy. On the facts of this case, no seizure of Mendenhall occurred.
Judgment/Outcome
The Court reversed the judgment of the Court of Appeals.
Mendenhall was walking through Detroit Metropolitan Airport when she was approached by narcotics agents. After some questions, the agents asked if Mendenhall would come to the DEA office, which she did. After entering the office, Mendenhall also allegedly consented to a search, where heroin was found on her.
Procedural History
The District Court denied the motion to suppress, finding that the initial approach of Mendenhall was permissible under Terry. The Court of Appeals reversed, finding that the search was not consented, but a product of earlier official conduct violative of the Fourth Amendment.
Issue(s)
Did the District Court err in finding that the narcotics agents’ initial questioning of Mendenhall was permissible?
Holding(s)
No.
Reasoning/Analysis
The Court found that a person is seized only when, by means of physical force or show of authority, his freedom of movement is restrained. As long as the person to whom questions are put remains free to disregard the questions and walk away, there has been no intrusion upon that person’s liberty or privacy. On the facts of this case, no seizure of Mendenhall occurred.
Judgment/Outcome
The Court reversed the judgment of the Court of Appeals.
United States v. Leon, 468 U.S. 897 (1984)
Facts
An informant of unproven reliability tipped the Burbank Police Department that Armando and Patsy were selling drugs from their residence. Police investigated and began to track individuals with a history of drug transactions coming and going from the residence. The police requested a search warrant, which was issued. The search turned up substantial quantities of cocaine and methaqualone.
Procedural History
Respondents moved to suppress the evidence. The District Court suppressed in part, finding that the affidavit was insufficient to establish probable cause but also that none of the respondents had standing to challenge all of the searches. The Court also found Officer Rombach acted in good faith.
Issue(s)
Does the exclusionary rule provide for an exception based on “good faith” of the officer?
Holding(s)
Yes.
Reasoning/Analysis
The Court looked at the history of exceptions created to the exclusionary rule and also found that they had yet to recognize a good-faith exception. But the balancing approach that has evolved during the years of experience with the rule provides strong support for the modification currently urged upon us. The marginal or nonexistent benefits produced by suppressing evidence obtained in objectively reasonable reliance on a subsequently invalidated search warrant cannot justify the substantial costs of exclusion. As applied to the facts, Officer Rombach’s affidavit was based on extensive investigation and the officer’s reliance on the magistrate’s determination of probable cause was objectively reasonable.
Judgment/Outcome
The Court reversed the judgment of the Court of Appeals.
An informant of unproven reliability tipped the Burbank Police Department that Armando and Patsy were selling drugs from their residence. Police investigated and began to track individuals with a history of drug transactions coming and going from the residence. The police requested a search warrant, which was issued. The search turned up substantial quantities of cocaine and methaqualone.
Procedural History
Respondents moved to suppress the evidence. The District Court suppressed in part, finding that the affidavit was insufficient to establish probable cause but also that none of the respondents had standing to challenge all of the searches. The Court also found Officer Rombach acted in good faith.
Issue(s)
Does the exclusionary rule provide for an exception based on “good faith” of the officer?
Holding(s)
Yes.
Reasoning/Analysis
The Court looked at the history of exceptions created to the exclusionary rule and also found that they had yet to recognize a good-faith exception. But the balancing approach that has evolved during the years of experience with the rule provides strong support for the modification currently urged upon us. The marginal or nonexistent benefits produced by suppressing evidence obtained in objectively reasonable reliance on a subsequently invalidated search warrant cannot justify the substantial costs of exclusion. As applied to the facts, Officer Rombach’s affidavit was based on extensive investigation and the officer’s reliance on the magistrate’s determination of probable cause was objectively reasonable.
Judgment/Outcome
The Court reversed the judgment of the Court of Appeals.
United States v. Draper, 358 U.S. 307 (1959)
Facts
Marsh was a narcotics agent who used the assistance of Hereford for tips. Hereford had been reliable in the past. Hereford told Marsh that Draper was selling drugs and would be arriving in Denver on one of two days with heroin. Hereford described Draper, down to what he would be wearing. Marsh saw Draper at the train station, stopped him, and in his search, discovered two envelopes containing heroin.
Procedural History
The District Court found that Marsh had probable cause to stop Draper without a warrant and denied the motion to suppress. The Court of Appeals affirmed.
Issue(s)
Did the lower courts err in finding that the description of Draper was sufficient to provide probable cause for the stop of Draper?
Holding(s)
No.
Reasoning/Analysis
Draper argued (1) that the evidence was hearsay and could not have been considered and (2) Marsh’s information should be held insufficient to show probable cause. The Court disagreed with Draper’s contentions and found that with every bit of Hereford’s information being verified, Marsh had reasonable grounds to believe that Draper would have heroin. We deal with probabilities, factual and practical considerations of everyday life on which reasonable and prudent men act.
Judgment/Outcome
The Court affirmed the judgment of the lower courts.
Concurring Opinions/Dissenting Opinions/Comments
Douglas dissented stating that if an arrest is made without a warrant, the offense must be committed in the presence of the officer or the officer must have reasonable grounds. The arresting officer did not have a bit of evidence.
Marsh was a narcotics agent who used the assistance of Hereford for tips. Hereford had been reliable in the past. Hereford told Marsh that Draper was selling drugs and would be arriving in Denver on one of two days with heroin. Hereford described Draper, down to what he would be wearing. Marsh saw Draper at the train station, stopped him, and in his search, discovered two envelopes containing heroin.
Procedural History
The District Court found that Marsh had probable cause to stop Draper without a warrant and denied the motion to suppress. The Court of Appeals affirmed.
Issue(s)
Did the lower courts err in finding that the description of Draper was sufficient to provide probable cause for the stop of Draper?
Holding(s)
No.
Reasoning/Analysis
Draper argued (1) that the evidence was hearsay and could not have been considered and (2) Marsh’s information should be held insufficient to show probable cause. The Court disagreed with Draper’s contentions and found that with every bit of Hereford’s information being verified, Marsh had reasonable grounds to believe that Draper would have heroin. We deal with probabilities, factual and practical considerations of everyday life on which reasonable and prudent men act.
Judgment/Outcome
The Court affirmed the judgment of the lower courts.
Concurring Opinions/Dissenting Opinions/Comments
Douglas dissented stating that if an arrest is made without a warrant, the offense must be committed in the presence of the officer or the officer must have reasonable grounds. The arresting officer did not have a bit of evidence.
United States v. Chadwick, 433 U.S. 1 (1977)
Facts
Amtrak officials noticed a footlocker was suspicious and alerted DEA agents in Boston. When arriving in Boston, the police dog signaled the presence of a controlled substance without alerting Machado and Leary. Chadwick met Machado and Leary and the three went to Chadwick’s car, when they were stopped. The footlocker was taken with the three arrestees to the federal building and was searched 1.5 hours after the arrests.
Procedural History
Respondents moved to suppress the marijuana obtained from the footlocker and the District Court held that the footlocker was not part of the area from which respondents might gain possession of a weapon or destructible evidence.
Issue(s)
Did the District Court err in suppressing the evidence obtained from the footlocker as not being within the area of gaining possession?
Holding(s)
No.
Reasoning/Analysis
The Court found that to safeguard himself and others, it has been held reasonable for the arresting officer to conduct a prompt, warrantless search of the arrestee and the area within their immediate control. Warrantless searches of luggage or property seized at the time of an arrest cannot be justified as incident to that arrest wither if the search is remote in time or place from the arrest.
Judgment/Outcome
The Court affirmed the judgment of the District Court.
Amtrak officials noticed a footlocker was suspicious and alerted DEA agents in Boston. When arriving in Boston, the police dog signaled the presence of a controlled substance without alerting Machado and Leary. Chadwick met Machado and Leary and the three went to Chadwick’s car, when they were stopped. The footlocker was taken with the three arrestees to the federal building and was searched 1.5 hours after the arrests.
Procedural History
Respondents moved to suppress the marijuana obtained from the footlocker and the District Court held that the footlocker was not part of the area from which respondents might gain possession of a weapon or destructible evidence.
Issue(s)
Did the District Court err in suppressing the evidence obtained from the footlocker as not being within the area of gaining possession?
Holding(s)
No.
Reasoning/Analysis
The Court found that to safeguard himself and others, it has been held reasonable for the arresting officer to conduct a prompt, warrantless search of the arrestee and the area within their immediate control. Warrantless searches of luggage or property seized at the time of an arrest cannot be justified as incident to that arrest wither if the search is remote in time or place from the arrest.
Judgment/Outcome
The Court affirmed the judgment of the District Court.
United States v. Carter, 884 F.2d 368 (8th Cir. 1989)
Facts
Postal inspectors placed marked bills and a bearer check in mail trays and tracked the stolen checks to Carter. Carter was interviewed in the bank president’s office by the inspectors and bank security manager for 1.5 hours. After obtaining incriminating statements, Carter was informed of his Miranda rights and he signed a handwritten admission of guilt.
Procedural History
Carter moved to suppress his statements and the bait money and the district court granted the motion, finding the interrogation occurred in a custodial setting.
Issue(s)
Did the district court err in suppressing the evidence on the grounds that the interrogation was in a custodial setting and that Carter’s statements were not voluntary?
Holding(s)
No.
Reasoning/Analysis
The Court found that in evaluating the factors of Carter’s interrogation (bank president’s office, isolation from others, not free to leave, and the length of interrogation) we discern no clear error in the conclusion that Carter could have reasonably believed the interrogation was custodial in nature.
Judgment/Outcome
The Court affirmed the judgment of the district court.
Postal inspectors placed marked bills and a bearer check in mail trays and tracked the stolen checks to Carter. Carter was interviewed in the bank president’s office by the inspectors and bank security manager for 1.5 hours. After obtaining incriminating statements, Carter was informed of his Miranda rights and he signed a handwritten admission of guilt.
Procedural History
Carter moved to suppress his statements and the bait money and the district court granted the motion, finding the interrogation occurred in a custodial setting.
Issue(s)
Did the district court err in suppressing the evidence on the grounds that the interrogation was in a custodial setting and that Carter’s statements were not voluntary?
Holding(s)
No.
Reasoning/Analysis
The Court found that in evaluating the factors of Carter’s interrogation (bank president’s office, isolation from others, not free to leave, and the length of interrogation) we discern no clear error in the conclusion that Carter could have reasonably believed the interrogation was custodial in nature.
Judgment/Outcome
The Court affirmed the judgment of the district court.
United States v. Ash, 413 U.S. 300 (1973)
Facts
A robbery was committed at a bank by a man wearing a stocking mask, waiving a pistol, and another entered, gathering the money. An informer told authorities that he had discussed the robbery with Ash and photos, including one of Ash, were shown to four witnesses. All four made uncertain identifications. In preparation for trial, the witnesses were shown a photographic display to determine whether the witnesses could make in-court identifications.
Procedural History
The Court of Appeals held that Ash’s right to counsel was violated when his attorney was not given the opportunity to be present at the photographic displays.
Issue(s)
Did the Court of Appeals err in finding that Ash’s Sixth Amendment rights had been violated?
Holding(s)
Yes.
Reasoning/Analysis
The Court found that Wade recognized times where the subsequent trial would cure a one-sided confrontation between prosecuting authorities and an uncounseled defendant. Such stages were not critical. Since the accused himself is not present at the time of the photographic display, no liability arises that the accused might be misled by his lack of familiarity with the law or overpowered by his professional adversary. We are not persuaded that the risks inherent in the use of photographic displays are so pernicious that an extraordinary system of safeguards is required.
Judgment/Outcome
The Court reversed and remanded the judgment of the Court of Appeals.
A robbery was committed at a bank by a man wearing a stocking mask, waiving a pistol, and another entered, gathering the money. An informer told authorities that he had discussed the robbery with Ash and photos, including one of Ash, were shown to four witnesses. All four made uncertain identifications. In preparation for trial, the witnesses were shown a photographic display to determine whether the witnesses could make in-court identifications.
Procedural History
The Court of Appeals held that Ash’s right to counsel was violated when his attorney was not given the opportunity to be present at the photographic displays.
Issue(s)
Did the Court of Appeals err in finding that Ash’s Sixth Amendment rights had been violated?
Holding(s)
Yes.
Reasoning/Analysis
The Court found that Wade recognized times where the subsequent trial would cure a one-sided confrontation between prosecuting authorities and an uncounseled defendant. Such stages were not critical. Since the accused himself is not present at the time of the photographic display, no liability arises that the accused might be misled by his lack of familiarity with the law or overpowered by his professional adversary. We are not persuaded that the risks inherent in the use of photographic displays are so pernicious that an extraordinary system of safeguards is required.
Judgment/Outcome
The Court reversed and remanded the judgment of the Court of Appeals.
Thornton v. United States, 124 S. Ct. 2127 (2004)
Facts
Nichols was driving an unmarked police car and noticed that Thornton seemed to avoid driving next to him. Nichols pulled off onto a side street and ran the tags on Nichols car. He discovered that the tags were for a two-door Chevrolet, not Thornton’s Lincoln Town Car. Thornton had pulled into a parking lot and Nichols stopped Thornton as he was walking from the car. After searching Thornton, with his consent, and discovering narcotics, Thornton was placed under arrest. Nichols then search Thornton’s car, finding a 9mm handgun under the driver’s seat.
Procedural History
Thornton sought to suppress the handgun but the District Court denied the motion. Thornton was convicted on all three counts.
Issue(s)
Did the lower courts err in admitting the evidence of the handgun when Thornton had been arrested and placed in the patrol car before the search occurred?
Holding(s)
No.
Reasoning/Analysis
The Court found that the arrest of a suspect who is next to a vehicle presents no identical concerns regarding officer safety and the destruction of evidence as the arrest of one who is inside the vehicle. It is unlikely that Thornton could have reached for the gun after he was outside his automobile, but the need for a clear rule justifies the sort of generalization which Belton enunciated. So long as an arrestee is the sort of recent occupant of a vehicle such as petitioner was here, officers may search that vehicle incident to the arrest.
Judgment/Outcome
The Court affirmed the judgment of the Court of Appeals.
Nichols was driving an unmarked police car and noticed that Thornton seemed to avoid driving next to him. Nichols pulled off onto a side street and ran the tags on Nichols car. He discovered that the tags were for a two-door Chevrolet, not Thornton’s Lincoln Town Car. Thornton had pulled into a parking lot and Nichols stopped Thornton as he was walking from the car. After searching Thornton, with his consent, and discovering narcotics, Thornton was placed under arrest. Nichols then search Thornton’s car, finding a 9mm handgun under the driver’s seat.
Procedural History
Thornton sought to suppress the handgun but the District Court denied the motion. Thornton was convicted on all three counts.
Issue(s)
Did the lower courts err in admitting the evidence of the handgun when Thornton had been arrested and placed in the patrol car before the search occurred?
Holding(s)
No.
Reasoning/Analysis
The Court found that the arrest of a suspect who is next to a vehicle presents no identical concerns regarding officer safety and the destruction of evidence as the arrest of one who is inside the vehicle. It is unlikely that Thornton could have reached for the gun after he was outside his automobile, but the need for a clear rule justifies the sort of generalization which Belton enunciated. So long as an arrestee is the sort of recent occupant of a vehicle such as petitioner was here, officers may search that vehicle incident to the arrest.
Judgment/Outcome
The Court affirmed the judgment of the Court of Appeals.
Terry v. Ohio, 392 U.S. 1 (1968)
Facts
Chilton and Terry were standing on a street corner and being observed by McFadden. Chilton and Terry would alternate walking down the street, peering in a store window, then returning to the corner. McFadden followed the men when they left and approached them, along with Katz. He asked for their names, then spun Terry around and patted the outside of his clothing. The men were directed into a store, where they were searched and McFadden removed a gun from both Terry and Chilton.
Procedural History
Terry and Chilton moved to suppress the guns and the court denied the motion, stating that McFadden had reasonable cause.
Issue(s)
Did the lower courts err in finding that McFadden had reasonable cause to stop and frisk Terry, thus making it a valid search under the Fourth Amendment?
Holding(s)
No.
Reasoning/Analysis
The Court found that there must be a narrowly drawn authority to permit a reasonable search for weapons where the officer has reason to believe that he is dealing with an armed and dangerous individual, regardless of whether he has probable cause to arrest the individual. It would be unreasonable for officers to take unnecessary risks in the performance of their duties. McFadden confined his search strictly to what was minimally necessary to determine whether the individuals were armed and to disarm them once he discovered the weapons. He did not conduct a general exploratory search.
Judgment/Outcome
The Court affirmed the judgment of the lower courts.
Chilton and Terry were standing on a street corner and being observed by McFadden. Chilton and Terry would alternate walking down the street, peering in a store window, then returning to the corner. McFadden followed the men when they left and approached them, along with Katz. He asked for their names, then spun Terry around and patted the outside of his clothing. The men were directed into a store, where they were searched and McFadden removed a gun from both Terry and Chilton.
Procedural History
Terry and Chilton moved to suppress the guns and the court denied the motion, stating that McFadden had reasonable cause.
Issue(s)
Did the lower courts err in finding that McFadden had reasonable cause to stop and frisk Terry, thus making it a valid search under the Fourth Amendment?
Holding(s)
No.
Reasoning/Analysis
The Court found that there must be a narrowly drawn authority to permit a reasonable search for weapons where the officer has reason to believe that he is dealing with an armed and dangerous individual, regardless of whether he has probable cause to arrest the individual. It would be unreasonable for officers to take unnecessary risks in the performance of their duties. McFadden confined his search strictly to what was minimally necessary to determine whether the individuals were armed and to disarm them once he discovered the weapons. He did not conduct a general exploratory search.
Judgment/Outcome
The Court affirmed the judgment of the lower courts.
Stoner v. California, 376 U.S. 483 (1964)
Facts
Officers arrived at hotel where they believed Stoner was staying. They asked the night clerk whether Stoner lived there and if they could search his room. The night clerk escorted them there and during their search, discovered glasses, a jacket, and a .45 caliber pistol.
Procedural History
Stoner moved to suppress the items found in the room, but the court denied his motion.
Issue(s)
Was the search of Stoner’s hotel room lawful because it was based upon the consent of the hotel clerk?
Holding(s)
No.
Reasoning/Analysis
The Court found that it was the petitioner’s constitutional right which was at stake, not the hotel clerk’s. It was a right, therefore, which only the petitioner could waive by word or deed. This search without a warrant was unlawful.
Judgment/Outcome
The Court reversed the judgment of the trial court.
Officers arrived at hotel where they believed Stoner was staying. They asked the night clerk whether Stoner lived there and if they could search his room. The night clerk escorted them there and during their search, discovered glasses, a jacket, and a .45 caliber pistol.
Procedural History
Stoner moved to suppress the items found in the room, but the court denied his motion.
Issue(s)
Was the search of Stoner’s hotel room lawful because it was based upon the consent of the hotel clerk?
Holding(s)
No.
Reasoning/Analysis
The Court found that it was the petitioner’s constitutional right which was at stake, not the hotel clerk’s. It was a right, therefore, which only the petitioner could waive by word or deed. This search without a warrant was unlawful.
Judgment/Outcome
The Court reversed the judgment of the trial court.
State v. Robalewski, 418 A.2d 817 (R.I. 1980)
Facts
Robalewski was an inmate at correctional facility who escaped after attacking a guard. Robalewski was traced to an apartment and officers entered, intending to arrest Robalewski. Robalewski was sitting at a kitchen table and placed under arrest. Another detective examined Robalewski’s jacket on a living room couch and found a revolver.
Procedural History
The revolver was introduced as evidence at Robalewski’s trial and he was convicted on six counts.
Issue(s)
Did the trial court err in admitting the revolver found in Robalewski’s jacket as incident to the arrest?
Holding(s)
Yes.
Reasoning/Analysis
The Court found that all of the trial justice’s justifications for admitting the revolver (no barrier, presence of other adults, lunge and leap, etc.) were in error and the record does not support the conclusion that the jacket lay within Robalewski’s immediate control at the time of his arrest.
Judgment/Outcome
The Court reversed and remanded the judgment of the trial court.
Robalewski was an inmate at correctional facility who escaped after attacking a guard. Robalewski was traced to an apartment and officers entered, intending to arrest Robalewski. Robalewski was sitting at a kitchen table and placed under arrest. Another detective examined Robalewski’s jacket on a living room couch and found a revolver.
Procedural History
The revolver was introduced as evidence at Robalewski’s trial and he was convicted on six counts.
Issue(s)
Did the trial court err in admitting the revolver found in Robalewski’s jacket as incident to the arrest?
Holding(s)
Yes.
Reasoning/Analysis
The Court found that all of the trial justice’s justifications for admitting the revolver (no barrier, presence of other adults, lunge and leap, etc.) were in error and the record does not support the conclusion that the jacket lay within Robalewski’s immediate control at the time of his arrest.
Judgment/Outcome
The Court reversed and remanded the judgment of the trial court.
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