United States v. Watson

United States v. Watson

United States Supreme Court
423 U.S. 411 (1976)

ISSUE: Did an officer violate D's 4th Amdt. rights when he made an arrest without a warrant after believing that D was in possession of stolen credit cards?
HOLDING: No, officers have a right to arrest without a warrant so long as they have PC.
FACTS:
  • The officer, a Postal Service officer, received a lead from an informant that D was in possession of a stolen credit card and had asked the informant to cooperate with him
  • The officer set up a meeting between D and the informant because D indicated he had more stolen cards
  • At the meeting, the informant gave the sign that D did have the cards with him, and the officer came in and arrested him
  • Following the arrest, D gave the officer permission to search his car, and the officer would two stolen credit cards in it
PROCEDURAL HISTORY:
  • Convicted of illegally possessing the two credit cards
  • Ct. App. reversed ruling that the evidence of the the two cards found in the car was inadmissible per the 4th Amdt.
RULES:
  • Carroll v. United States: Usual rule is that a police officer may arrest without warrant one believed by the officer upon reasonable cause to have been guilty of a felony
  • CL rule: A peace officer was permitted to arrest without a warrant for a misdemeanor or a felony committed in his presence as well as for a felony not committed in his presence if there was reasonable ground for making the arrest
REASONING:
  • Valid arrest: A federal statute authorized the officer to make arrests for felonies if the officer has reasonable grounds to believe that the person to be arrested had committed the felony
    • Reasonable grounds = PC, which the officer had
    • Statute authorizing postal inspectors to arrest without warrants represents a judgment by Congress that it is not unreasonable under the 4th Amdt. for postal inspectors to arrest without a warrant provided that they have PC to do so
  • No warrant requirement for such arrest: Never required a warrant to make an arrest for a felony so long as there's PC
    • Officers may still seek warrants where practicable to do so
COMMENTS:
  • Important that D was not in a house but rather was in a restaurant
  • Public vs. private place:
    • Public place = do NOT need warrant to make arrest
    • In home (or hotel room) = NEED warrant to make arrest
OTHER CASES:
  • Gerstein v. Pugh: The 4th Amdt. requires a judicial determination of PC as a prerequisite to extended restraint on liberty following arrest either before or promptly following arrest
  • County of Riverside v. McLaughlin: PC determination made within 48 hours of arrest ordinarily will comply with promptness requirement
    • Anything over that and the burden shifts to the govt. to demonstrate the existence of a bona fide emergency  or other extraordinary circumstance

 

Leave a Reply