Hayes v. Florida

Hayes v. Florida Case Brief

United States Supreme Court
470 U.S. 811 (1985)

ISSUE: May the police take a suspect to the police station for the purpose of fingerprinting the individual if they do not have PC to make an arrest but they do have reasonable suspicion?
HOLDING: No.
FACTS:
  • A string of burglary-rapes had occurred in a particular city, and police had recovered fingerprints from a doorknob in one of the victims' houses
  • Police suspected D of the crimes, so they went to his house and when he refused to voluntarily go to the station, the police told him that they'd arrest him if he didn't go
  • D went to the police station, was fingerprinted, and his prints matched those found at the scene of the crime
PROCEDURAL HISTORY:
  • Trial Ct. denied motion to suppress
RULES:
  • Davis v. Mississippi: An individual's detention for the purpose of fingerprinting was subject to the constraints of the 4th Amdt. and exceeded the permissible scope under Terry
  • Dunaway v. New York: Transportation to and investigative detention at the police station without PC or judicial authorization together violate the 4th Amdt.
REASONING:
  • Line crossed: A line is crossed when the police, without PC or a warrant, forcibly remove a person from his home or other place in which he is entitled to be and transport him to the police station where he is detained, although briefly, for investigative purposes
    • Brief detention in the field for fingerprinting is not necessarily impermissible under the 4th Amdt. so long as there's reasonable suspicion

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