Criminal Procedure Supreme Court Cases: Fourth, Fifth & Sixth Amendments

Weeks v. United States (1914)

Background & Origin: Federal agents entered Freemont Weeks' house without a search warrant and seized papers and letters used to convict him of transporting lottery tickets through the mail. Key Arguments & Ruling: The Supreme Court held that the warrantless seizure of items from a private residence violated the Fourth Amendment. This case created the Exclusionary Rule, stating that illegally obtained evidence cannot be used in court. Impact & Precedent: Established the Exclusionary Rule, though it initially applied only to federal law enforcement (the "silver platter doctrine" allowed federal prosecutors to still use illegally seized state evidence). Key Fact to Remember: Created the Exclusionary Rule at the federal level.

Carroll v. United States (1925)

Background & Origin: Undercover Prohibition agents arranged to buy illegal liquor from George Carroll. Later, seeing Carroll driving on a highway known for bootlegging, they pulled him over without a warrant and searched the car, finding hidden alcohol behind the seat upholstery. Key Arguments & Ruling: The Court ruled that the search was constitutional because vehicles are mobile and can quickly leave a jurisdiction while a warrant is being obtained. Impact & Precedent: Created the Automobile Exception to the Fourth Amendment. Officers may search a vehicle without a warrant if they have probable cause to believe it contains contraband or evidence of a crime. Key Fact to Remember: Birth of the Automobile Exception.

Katz v. United States (1967)

Background & Origin: FBI agents attached an eavesdropping device to the outside of a public telephone booth to listen to Charles Katz transmitting illegal gambling wagers. Key Arguments & Ruling: The government argued there was no physical trespass into a private room. The Supreme Court rejected this, ruling that the Fourth Amendment protects people, not places. Impact & Precedent: Created the Reasonable Expectation of Privacy test (further refined by Justice Harlan's concurrence: 1. A person exhibited an actual expectation of privacy, and 2. That expectation is one society recognizes as reasonable). Overturned the physical trespass standard. Key Fact to Remember: Shifted Fourth Amendment protection from physical locations to reasonable expectations of privacy.

Terry v. Ohio (1968)

Background & Origin: A plainclothes police officer observed John Terry and two other men pacing back and forth in front of a store window in a manner suggesting a "casing" for an armed robbery. The officer stopped them and patted down their outer clothing, finding weapons.

Key Arguments & Ruling: The Court held that police officers may briefly detain a person based on reasonable suspicion of criminal activity and pat down their outer clothing for weapons if they reasonably suspect the person is armed and dangerous.

Impact & Precedent: Established the legality of the "Stop and Frisk" procedure and created a lower standard than probable cause ("reasonable suspicion") for brief investigatory stops and weapons searches.

Key Fact to Remember: Created "Stop and Frisk" under the lower standard of reasonable suspicion.

Chimel v. California (1969)

Background & Origin: Officers arrived at Ted Chimel's home with an arrest warrant for coin shop burglary. Upon placing him under arrest, officers searched his entire three-bedroom house, attic, garage, and drawers without a separate search warrant.

Key Arguments & Ruling: The Court held that a search incident to a lawful arrest is limited to the arrestee's person and the area within their immediate control (their "grab area" or "wingspan").

Impact & Precedent: Defined the boundary of a Search Incident to Lawful Arrest (SILA) to prevent officers from conducting sweeping home searches without a search warrant.

Key Fact to Remember: Limits arrest searches to the suspect's immediate grab area ("wingspan").

Mapp v. Ohio (1961)

Background & Origin: Cleveland police forcibly entered Dollree Mapp's home looking for a bombing suspect. They failed to find the suspect but discovered obscene material in a trunk, which they used to convict her. Officers claimed to have a warrant but never produced one.

Key Arguments & Ruling: The Supreme Court held that evidence obtained through searches and seizures in violation of the Fourth Amendment is inadmissible in state courts.

Impact & Precedent: Incorporated the Exclusionary Rule to all state law enforcement through the Fourteenth Amendment's Due Process Clause (extending the Weeks rule to the states).

Key Fact to Remember: Applied the Exclusionary Rule to state courts and local police.

Tennessee v. Garner (1985)

Background & Origin: Memphis police officers responded to a burglary call. Officer Elton Hymon saw an unarmed 15-year-old suspect, Edward Garner, fleeing across a backyard. To prevent escape, Hymon shot Garner in the back of the head, killing him, per a Tennessee statute allowing deadly force against fleeing felons.

Key Arguments & Ruling: The Court held that deadly force may not be used against a fleeing suspect unless the officer has probable cause to believe that the suspect poses a significant threat of death or serious physical injury to the officer or others.

Impact & Precedent: Struck down the common law "fleeing felon rule" and established Fourth Amendment limits on officer use of deadly force.

Key Fact to Remember: Deadly force cannot be used solely to stop a fleeing suspect unless they pose an imminent threat.

Graham v. Connor (1989)

Background & Origin: Dethorne Graham, a diabetic experiencing an insulin reaction, had a friend drive him to a store for orange juice. Seeing a long line, Graham rushed out to go to a friend's house instead. Officer Connor found this suspicious, made a traffic stop, and held Graham, resulting in physical injuries to Graham despite explanations of his medical condition.

Key Arguments & Ruling: The Supreme Court ruled that all claims of excessive force by law enforcement officers must be analyzed under the Fourth Amendment's "Objective Reasonableness" standard, rather than a Fourteenth Amendment substantive due process standard.

Impact & Precedent: Established that an officer's actions must be judged from the perspective of a reasonable officer on the scene, rather than with 20/20 hindsight.

Key Fact to Remember: Established the "Objective Reasonableness" standard for police use of force.

Maryland v. Wilson (1997)

Background & Origin: A state trooper pulled over a car for speeding. During the stop, the officer ordered the passenger, Jerry Lee Wilson, out of the vehicle. As Wilson exited, a quantity of crack cocaine fell to the ground.

Key Arguments & Ruling: Building on Pennsylvania v. Mimms (which allowed officers to order drivers out of cars), the Court held that an officer making a lawful traffic stop may order passengers out of the car pending completion of the stop.

Impact & Precedent: Expanded officer safety protections during routine traffic stops to include control over all vehicle occupants.

Key Fact to Remember: Officers can order both drivers AND passengers out of a vehicle during a traffic stop.

Missouri v. McNeely (2013)

Background & Origin: Tyler McNeely was stopped for speeding and swerving. After refusing a breath test, he was taken to a hospital where a blood sample was drawn without a search warrant, despite his refusal.

Key Arguments & Ruling: The state argued that the natural dissipation of alcohol in the bloodstream creates an automatic exigent circumstance. The Supreme Court disagreed, ruling that natural dissipation does not create a categorical exigent circumstance exception.

Impact & Precedent: Police must obtain a warrant for a blood draw in routine drunk driving cases unless specific exigent circumstances make obtaining a warrant impractical.

Key Fact to Remember: Natural dissipation of alcohol alone does not justify a warrantless blood draw.

Maryland v. King (2013)

Background & Origin: Alonzo Jay King Jr. was arrested on assault charges. As part of a routine booking procedure under Maryland law, officers took a cheek swab for DNA, which matched unsolved evidence from a 2003 rape.

Key Arguments & Ruling: The Supreme Court held that taking and analyzing a cheek swab for DNA from individuals arrested for serious crimes is a reasonable search under the Fourth Amendment.

Impact & Precedent: Categorized DNA cheek swabs as a legitimate booking procedure similar to fingerprinting and photographing.

Key Fact to Remember: Police can take DNA cheek swabs of arrestees as part of routine booking.

Powell v. Alabama (1932)

Background & Origin: Nine young Black men ("The Scottsboro Boys") were accused of raping two white women on a train. Their trials were completed in a single day with appointed counsel who did no preparation or defense work.

Key Arguments & Ruling: The Supreme Court held that the right to counsel in capital cases (cases involving the death penalty) is a fundamental requirement of due process under the Fourteenth Amendment.

Impact & Precedent: First time the Supreme Court reversed a state conviction for failing to provide adequate legal counsel.

Key Fact to Remember: Guaranteed court-appointed counsel in capital (death penalty) cases.

Escobedo v. Illinois (1964)

Background & Origin: Danny Escobedo was arrested for murder and taken to police headquarters. He repeatedly requested to speak to his lawyer, and his lawyer arrived at the station asking to see Escobedo, but police refused access and continued interrogating him until he made incriminating statements.

Key Arguments & Ruling: The Court ruled that suspects have a right to counsel during police interrogations under the Sixth Amendment once the investigation shifts from general inquiry to an accusatory stage.

Impact & Precedent: Extended the Sixth Amendment right to counsel to the interrogation stage, prior to formal indictment.

Key Fact to Remember: Right to consult an attorney during police interrogation.

Miranda v. Arizona (1966)

Background & Origin: Ernesto Miranda was arrested for kidnapping and rape, interrogated for two hours, and signed a written confession without being informed of his right to remain silent or right to an attorney.

Key Arguments & Ruling: The Court held that custodial interrogation is inherently coercive. Under the Fifth Amendment, statements made by a suspect during custodial interrogation are admissible only if the police inform the suspect of their rights and the suspect knowingly waives them.

Impact & Precedent: Created the Miranda Warnings (Right to remain silent, anything said can be used in court, right to an attorney, right to appointed counsel if indigent).

Key Fact to Remember: Required police to read rights prior to custodial interrogation.

Gideon v. Wainwright (1963)

Clarence Earl Gideon was charged in Florida state court with breaking and entering a pool hall (a felony). He requested an attorney because he was indigent, but Florida law only provided counsel in capital cases. Gideon represented himself and wThe Supreme Court unanimously ruled that the Sixth Amendment's guarantee of counsel is a fundamental right essential to a fair trial, made applicable to states through the Fourteenth Amendment.

Impact & Precedent: Guaranteed court-appointed attorneys to indigent defendants charged with felonies in state court.

Key Fact to Remember: Guaranteed public defenders for indigent defendants in all felony cases.

Argersinger v. Hamlin (1972)

Jon Argersinger, a man in Florida, was charged with carrying a concealed weapon (a misdemeanor carrying up to 6 months imprisonment). He was tried without a lawyer and sentenced to 90 days in jail.

The Supreme Court said that no person may be imprisoned for any offense (felony or misdemeanor) unless they were provided with the opportunity to be represented by counsel.