Criminal Procedure- Midterm Cases Review

Weeks v. United States (1914)

• Facts: Police entered home without a warrant, searched it, and seized papers. Federal marshals later returned and took more. He was charged with using the mail to transport lottery tickets.

• Ruling: The warrantless search and seizure violated the 4th Amendment. Evidence obtained this way is excluded from federal prosecutions (the origin of the federal exclusionary rule).

Wolf v. Colorado (1949)

• Facts: was convicted of conspiring to perform abortions. The evidence was an appointment book seized without a warrant.

• Ruling: The 4th Amendment’s core protection against arbitrary police intrusion applies to the states through the 14th Amendment. But the exclusionary rule was not required in state courts, so the conviction stood.

Rochin v. California (1952)

• Facts: Deputies entered home without a warrant and saw him swallow two capsules. After a struggle, they took him to a hospital, where a doctor pumped his stomach against his will and recovered morphine capsules.

• Ruling: The conduct “shocks the conscience” and violates 14th Amendment due process. The conviction was reversed.

Draper v. United States (1959)

• Facts: A reliable informant told a narcotics agent that would arrive by train from Chicago with heroin, and described his clothing and gait. The agent saw a man matching that description and arrested him without a warrant, finding heroin.

• Ruling: The arrest was valid. The agent verified the informant’s details, which established probable cause. Probable cause rests on probabilities and need not be proof admissible at trial.

Mapp v. Ohio (1961)

• Facts: Police forced their way into home looking for a bombing suspect, claiming to have a warrant (none was produced). They found obscene materials, and she was convicted of possession.

• Ruling: The exclusionary rule applies to the states through the 14th Amendment. Evidence from unconstitutional searches is inadmissible in state courts, overruling Wolf on that point.

Katz v. United States (1967)

• Facts: The FBI attached a recording device to the outside of a public phone booth and recorded placing illegal bets. There was no warrant.

• Ruling: The 4th Amendment “protects people, not places.” The recording was a search. Under Justice Harlan’s concurrence, a search occurs when a person has an actual expectation of privacy that society recognizes as reasonable

Warden v. Hayden (1967)

• Facts: After an armed robbery, police followed the robber to a house minutes later. They entered without a warrant, found individual and seized clothing matching the description.

• Ruling: Hot pursuit is an exigent circumstance that justifies warrantless entry and search. The Court also dropped the “mere evidence” rule, so items like clothing can be seized

Coolidge v. New Hampshire (1971)

• Facts: In a murder investigation, police seized car from his driveway under a warrant issued by the state attorney general, who was also running the investigation. Vacuum sweepings from the car were used against him.

• Ruling: The warrant was invalid because the issuer was not a neutral and detached magistrate. Plain view did not save the seizure because police had long known about the car and planned to take it, so the discovery was not inadvertent.

Payton v. New York (1980)

• Facts: Detectives had probable cause that individual committed murder. They broke into his apartment without an arrest warrant, found no one, and seized a shell casing in plain view.

• Ruling: Absent exigent circumstances or consent, police need an arrest warrant to enter a suspect’s home to arrest him.

Steagald v. United States (1981)

• Facts: DEA agents had an arrest warrant for Lyons and learned he might be at individual house. They entered without a search warrant, did not find Lyons, and found cocaine.

• Ruling: An arrest warrant does not authorize entering a third party’s home. Police need a search warrant for that home, absent consent or exigent circumstances.

Welsh v. Wisconsin (1984)

• Facts: A driver crashed into a field and walked home. Police went to his house, entered without a warrant, and arrested him in bed for DWI. It was a first offense, a non-jailable civil violation in Wisconsin.

• Ruling: A warrantless home entry to arrest for a minor offense is not justified by exigent circumstances (here, evaporating blood alcohol). The seriousness of the offense matters.

Tennessee v. Garner (1985)

• Facts: An officer shot and killed Edward Garner, an unarmed 15-year-old fleeing over a fence after a burglary. A state statute allowed deadly force against fleeing felons.

• Ruling: Deadly force is a seizure and must be reasonable. It is allowed only if the officer has probable cause to believe the suspect poses a significant threat of death or serious injury to the officer or others.

California v. Greenwood (1988)

• Facts: Police had the garbage collector hand over opaque trash bags from the curb. They found drug evidence and used it to get a warrant.

• Ruling: No reasonable expectation of privacy in trash left at the curb for collection. It is exposed to the public, so no warrant was needed.

California v. Hodari D. (1991)

• Facts: Youths ran when unmarked police cars approached. Individual threw away crack cocaine while running, then was tackled.

• Ruling: A seizure requires physical force or submission to a show of authority. He was not seized until tackled, so the cocaine was abandoned before the seizure and was admissible.

Minnesota v. Dickerson (1993)

• Facts: Officers stopped individual as he left a known crack house and frisked him. The officer felt a lump in his pocket, manipulated it, and concluded it was crack cocaine.

• Ruling: The “plain feel” doctrine is valid if the object’s identity is immediately apparent during a lawful frisk. Here the officer had to squeeze and manipulate it, which went beyond a Terry frisk, so the evidence was suppressed.

Kyllo v. United States (2001)

• Facts: Agents aimed a thermal imager at Individual home from the street to detect heat from marijuana grow lamps. They used the readings to get a warrant.

• Ruling: Using sense-enhancing technology not in general public use to learn details of a home’s interior is a search. It requires a warrant.

Herring v. United States (2009)

• Facts: An officer arrested individual based on a warrant that a neighboring county’s records showed as active. The warrant had actually been recalled, but the database was not updated through negligence. A search incident to arrest turned up drugs and a gun.

• Ruling: The exclusionary rule does not apply when the error comes from isolated negligence, since exclusion would deter little and cost too much.

Florida v. Jardines (2013)

• Facts: Police took a drug-sniffing dog onto individual front porch on an unverified tip. The dog alerted, police got a warrant, and they found marijuana plants.

• Ruling: The porch is curtilage. The implied license to approach a front door does not cover bringing a trained dog to investigate, so it was a search requiring a warrant