Important cases Criminal Prosecution Exam 2

Important cases that need to be remembered for the second exam and what needs to be known about the cases. Know the holding of each case.

Alabama v. White(1990)

An anonymous called told Montgomery Alabama police that Vanessa Rose White had cocaine in an attache case in her car. The caller gave certain specific details about the car and White’s future movements. Following that tip, the police followed Vanessa as she drove from an apartment to Dob’s motel court, where they pulled her over.

Reasonable Suspicion:

• less demanding standard than probable cause. it can be established with information different in quantity or content from that required to establish probable cause.

• “More likely than not”

• Officer May consider:

  • Prior criminal record of the suspect

  • highly suspicious conduct

  • presence of incriminating evidence

  • description given of the perpetrator

  • flight, admissions, unusual hour, and failure to answer questions

  • presence of suspect in a high crime area

  • suspect’s reputation from criminal activity

Stop and Frisk:

• A stop can be valid if information given by an anonymous tipster can be corroborated

• In this case, a description of the person carrying the narcotics, what she would be wearing, what time she would leave her apartment, and her destination was given to the police

Lawrence v Texas(2003)

• landmark supreme court case that struck down state laws criminalizing sodomy between consenting adults

• john Lawrence and tyron garner were arrested in Lawrence’s Houston apartment for engaging in same-sex activity; which was illegal under Texas law at the time

• ruled that texas sodomy law violated the due process clause of the fourteenth amendment

• overturned bowers v Hardwick

Obergefell v Hodges(2015)

• legalized same-sex marriage nationwide, the court ruled that the fundamental right to marry is guaranteed to same-sex couples by both the due process clause and the equal protection clause of the fourteenth amendment

• required all 50 states, district of Columbia, and U.S. territories to preform and recognize same sex marriage

• overturned the previous precendent by baker v nelson

• it established marriage equality, improved the well-being of lgbt adults, and laid the groundwork for further advancements in lgbtq+ rights

Maryland v Pringle(2003)

In determining probable cause, the term “man of reasonable caution” is best interpreted using the standard of an “objectively reasonable police officer”

The Supreme Court recognized that a police officer's observations and experience play a critical role in assessing the overall circumstances leading to an arrest. In this case, the court upheld that probable cause exists when the facts and circumstances within the officer's knowledge are sufficient to warrant a reasonable belief that a crime has been committed,

Weeks v Ohio(1914)

Fremont Weeks was arrested and evidence obtained through an unlawful search of his home was used against him in court. The Supreme Court ruled that the Fourth Amendment rights protecting citizens against unreasonable searches and seizures were violated, thus excluding the evidence obtained without a warrant.

• established the exclusionary rule as a fundamental principle of law that prohibits the use of illegally obtained evidence in federal prosecutions

• First applied to all federal prosecutions in this case

• set the precedent for the protection of constitutional rights in criminal cases.

Silverthorne Lumber Co. v United States(1920)

• expanded fourth amendment protections against illegal searches and seizures

• The case arose from a series of events involving the Silverthorne Lumber Company and its owners

• illegal seizure through an unauthorized raid on the Silverthorne Lumber Company’s office

• use of illegally obtained evidence

• refusal to comply

• exclusionary rule expansion

Once the primary evidence(the three) is shown to have been unlawfully obtained, and secondary evidence(the fruit) derived from it is also inadmissible

• The “fruit of the poisonous tree” doctrine

Wren v United States(1996)

plain clothes officers stopped a vehicle for a minor traffic violation. Upon approaching the car, they observed drugs in plain view, leading to the arrest of Michael and james

• addressed the constitutionality of pretextual traffic stops under the Fourth Amendment

• the court unanimously held that as long as officers have probable cause to believe a traffic violation occurred, the stop is constitutional regardless of the officer’s subjective intentions

• emphasized that the fourth amendment’s reasonableness standard is objective, not based on the officer’s subjective intent.

• decision affirmed that probable cause for a traffic violation justifies a stop regardless of any pretext

• raised concerns about potential racial profiling in traffic stops

Terry v ohio(1968)

detective martin McFadden observed john and two other men behaving suspiciously near a store in Cleveland, McFadden approached them, conducted a pat-down and discovered weapons.

• the court considered whether stop-and-frisk procedures violated the fourth amendment’s protection against unreasonable searches and seizures

• ruling held that police officers could stop and frisk individuals based on reasonable suspicion, and standard lower than probable cause

• legalized stop-and-frisk procedures under certain circumstances

• significantly influence law enforcement practices and fourth amendment interpretations

United states v Sokolow(1989)

DEA agents stopped Andrew at Honolulu international airport based on several suspicious factors including:

• paying 2,100 for plane tickets with case from a roll of $20 bills

• traveling under a name that didn’t match his phone listing

• flying to and from Miami(a known drug source city)

• appearing nervous and checking no luggage

the ruling held that the DEA agents did have reasonable suspicion to stop Sokolow The

• emphasized evaluating the totality of circumstances rather than individual factors in isolation

• It rejected the Ninth Circuit’s rigid two-part test for reasonable suspicion

• expanded law enforcement’s ability to conduct brief investigative stops based on a combination of factors

• raised concerns for potential erosion of the fourth amendment protections

United states v Mendenhall(1980)

DEA agents approached Sylvia at detriot metropolitan airport suspecting her of drug trafficking based on a “drug courier profile” Sylvia consented to accompany them to their office and undergo a search where a female officer discovered herion during the search, leading to her arrest

• legality issues on whether or mot her fourth amendment rights were violated during the encounter and subsequent search

• court held that her fourth amendment rights were not violated

• the encounter between the arrestee and the DEA agents did not constitute a siezure under the fourt amendment

• a person is seized only when, by means of physical force or show of authority; their freedom of movement is restrained

• her consent to accompany the agents and undergo a search was voluntary

Griswold v Connecticut(1965)

Executive director of Planned Parenthood League of Connecticut and a Yale Medical School professor were arrested for providing contraception information and devices to married couples

• The constitutionality of Connecticut’s law banning contraception use and assistance in using contraceptives

• The Supreme Court struck down the Connecticut law as unconstitutional

• The court established a constitutional right to privacy, particularly within marriage

• the court found that the right to marital privacy fell within this protected zone

• established the basis for the right to privacy in intimate practices

• paved the way for future cases expanding reproductive rights, including access to contraception for unmarried couples and abortion rights

Jenkins v Georgia(1974)

a theater manager in Albany, Georgia was convicted of distributing obscene material for showing the film “ carnal knowledge”

• the constitutionality of Georgia obscenity law and its application to the film “ carnal knowledge”

• the ruling unanimously overturned Jenkin’s conviction

• nudity alone is not sufficient to make material legally obscene

• state have latitude in defining “ contemporary community standards” but there are limits to what can be considered obscene

• the decision affirmed that the first amendment protects films with sexual themes and nudity from obscenity charges

Stanely v Georgia(1969)

Robert was suspected of bookmaking activities, police searches his home with a warrant for bookmaking evidence, and instead they found and seized three reels of obscene films

• Georgia’s law criminalizing private possession of obscene material was constitutional

• the court held that the law was unconstitutional

• the first amendment as applied to states through the fourteenth amendment prohibits criminalizing mere private possession of obscene material

• individuals have the right to privacy in their own homes, including the right to possess and view materials of their choice

• the court distinguished between public distribution of obscenity and private possession

• the decision affirmed that the constitution protects the right to review information and ideas, regardless of their perceived social worth

Illinois v Wardlow(2000)

Where an individual runs after seeing the police in a high crime neighborhood, enough reasonable suspicion exists for a Terry stop

• the court recognized that such flight can indicate a willingness to avoid police questioning and may suggest criminal involvement

• in circumstances where the behavior being observed is heightened by the surrounding context, officers are justified in stopping the individual to investigate further

Utah v Strief(2016)

The Court held that the presence of the valid arrest warrant was sufficient to sever the link between the initial unlawful stop and the subsequent discovery of drug evidence on Strief’s person.

This case established that even when an initial stop is found to be unlawful, the presence of a valid warrant can provide the legal basis for the arrest and the admissibility of evidence, reinforcing the importance of proper procedural conduct in law enforcement.

Brinegar v United States(1949)

The case involved a truck driven by Brinegar, which was stopped by federal officers who suspected it was carrying illegal liquor. The Court ruled that probable cause exists when the facts and circumstances within the officer's knowledge are sufficient to warrant a reasonable belief that a crime is being committed.

probable cause is:

• more than bare suspicion

• reasonably trustworthy information

• man of reasonable caution

  • emphasizing that reasonable conclusions can be drawn from the totality of circumstances, including the officer's observations and experience.

Illinois v Gates(1983)

police received an anonymous letter alleging lance and Susan were involved in drug trafficking, based on the letter and subsequent investigation, police obtained a search warrant for the gates home and car. the search uncovered drugs, weapons, and other contraband

• whether the two-pronged test for evaluating probable cause based on informant tips should be replaced with a more flexible standard

• the court overturned the Illinois courts decisions and ruled in favor of the state

• the court abandoned the rigid two-pronged test and established the “totality of circumstances” approach for determining probable cause

• this new standard allows judges to consider all available information and circumstances to determine if there’s a fair probability that evidence of a crime will be found

• The Court recognized that the previous test was too rigid and did not reflect the realities of law enforcement.

• Significantly altered the landscape of Fourth Amendment jurisprudence regarding search warrants.

• Provided law enforcement with a more flexible standard for establishing probable cause.

• Aimed to balance effective law enforcement with the protection of individual constitutional rights.

Elkins v United states(1960)

1. Background:

   • James Butler Elkins and others were indicted in federal court for intercepting and divulging telephone communications.

   • Evidence used against them was originally seized by state police during a search of Elkins' home, which Oregon courts had ruled unlawful.

2. Legal issue:

   • Whether evidence obtained illegally by state officers, without federal involvement, was admissible in federal criminal trials.

3. Decision:

   • In a 5-4 ruling, the Supreme Court held that such evidence was inadmissible in federal criminal trials.

   • The Court overturned the "silver platter doctrine," which had allowed federal prosecutors to use evidence illegally gathered by state police.

   • Evidence obtained by state officers during a search that would violate the Fourth Amendment if conducted by federal officers is inadmissible in federal criminal trials.

   • Significantly altered the landscape of Fourth Amendment jurisprudence regarding search and seizure.

   • Prepared the way for Mapp v. Ohio (1961), which applied the exclusionary rule to state courts.

   • Enhanced protection of individual rights against unreasonable searches and seizures.

Mapp v Ohio(1961)

1. Background:

   • Police searched Dollree Mapp's home without a valid warrant, finding obscene materials.

   • Mapp was convicted of possessing these materials under Ohio law.

2. Legal issue:

   • Whether evidence obtained through an illegal search was admissible in state courts.

3. Decision:

   • In a 6-3 ruling, the Supreme Court overturned Mapp's conviction.

   • The exclusionary rule, which prohibits the use of illegally obtained evidence, applies to state courts through the Fourteenth Amendment.

   • Evidence obtained in violation of the Fourth Amendment is inadmissible in state criminal trials.

   • The Court held that the exclusionary rule is an essential part of both the Fourth and Fourteenth Amendments.

   • Applying the rule to states was necessary to protect constitutional rights and deter police misconduct.

4. Impact:

   • Significantly altered state law enforcement procedures across the United States.

   • Extended Fourth Amendment protections to state-level criminal proceedings.

   • Overturned the previous ruling in Wolf v. Colorado, which had not required states to follow the exclusionary rule.

Navarette v California(2014)

• an anonymous caller reported a pickup truck that had run the caller of the road.

• police located the truck and discovered marijuanna in the vehicle

• the court upheld the validity of the stop, ruling that the anonymous tip was sufficient to establish reasonable suspicion

• the decision emphasized that if a tip provides a specific report of illegal activity, police may rely on it to justify a traffic stop; even when the caller’s identity is unknown