Chapter 4: Searches and Seizures - Key Concepts
Fourth Amendment
- Defines the right to be secure against unreasonable searches and seizures; warrants require probable cause, oath/affirmation, and particular description of place to be searched and items to be seized.
- Applies to persons, houses, papers, and effects.
Basic Limitation on Searches
- Searches must be narrow in scope; general searches are unconstitutional.
- Officers must know and operate within the law; consequences for noncompliance are severe.
- Evidence from illegal searches is not admissible at trial.
Exclusionary Rule
- Weeks v. United States (1914): Courts may not admit evidence obtained by unreasonable search and seizure; initially not applicable to states.
- Mapp v. Ohio (1967): Exclusionary Rule made applicable to all states.
Fruit of the Poisonous Tree Doctrine
- Evidence derived from an earlier illegality must be excluded.
- Courts aim to deter illegal police conduct; there are two exceptions to the doctrine (one example discussed elsewhere).
Inevitable Discovery
- Nix v. Williams (1984): If illegally obtained evidence would have been discovered lawfully anyway, it may be admitted.
- Rationale: Exclusion would not enhance integrity or fairness in such cases.
Justification for Reasonable Searches
- Searches with a warrant are valid if issued properly.
- Other justifications: consent, stop of a suspicious person who may be armed, incident to a lawful arrest, emergency, and parole/probation.
Good Faith
- United States v. Leon (1984): Good-faith exception; illegally obtained evidence may be admissible if police acted with objective good faith and were truly unaware of a violation; applies to search warrants.
Warrants
- Probable Cause: facts and circumstances known to the officer would lead a reasonable person to believe that crime-related evidence is at the place or on the person to be searched.
- Needs to be more than a mere hunch; less than beyond a reasonable doubt.
- Aguilar v. Texas (1964): Two-prong test—informant reliability and information believability.
- Illinois v. Gates (1983): Replaced with the Totality of the Circumstances test.
Totality of the Circumstances
- The court considers the sum of all factors to determine whether probable cause exists.
Search Warrants (Grounds)
- Penal Code 1524 outlines grounds to obtain a search warrant: stolen/embezzled property; used to commit a felony; possessed with intent to commit a felony; possession by another to conceal or prevent discovery; evidence tending to show a felony; evidence of sexual exploitation of a child; warrant to arrest a person.
Anticipatory Warrant
- Warrants based on probable evidence that a particular result will occur (e.g., seizure of specified items when a triggering condition happens).
Knock and Notice
- Wilson v. Arkansas (1995): Announce presence before entering a residence.
- Purposes: protect privacy, reduce risk of violence, prevent destruction of private property.
Consent
- Must be voluntary and freely given.
- Search limited to the area covered by consent.
- Consent should be a general request; can revoke consent at any time during the search.
Pat Down Frisk
- Exception to the warrant requirement when investigating suspicious circumstances or identifying a suspect from an APB.
- Reasonable suspicion required.
Terry v. Ohio (1968)
- Established the pat-down (frisk) for weapons for officer safety.
- Upheld when: carrying suspicious objects, vague answers, failure to identify, appearing out of place.
Incident to Arrest
- Protective Sweep: Supreme Court recognized for officer safety; requires reasonable suspicion and limited to areas where a person might be hiding.
Exigent Circumstances
- New York v. Quarles (1984): Exceptions to the warrant requirement to protect life, prevent destruction of property, prevent destruction of evidence, or prevent suspect escape.
Vehicle Searches
- New York v. Belton (1981): Bright-line rule; after probable cause to arrest, it is reasonable to search the entire passenger compartment for safety and evidence preservation.
- Arizona v. Gant (2008): A vehicle search incident to arrest is reasonable if: the arrestee might access the vehicle at the time of the search; or the vehicle contains evidence of the offense for which the arrestee was arrested.
- Pretext Stops; Inventory Searches: Additional vehicle search considerations.
Plain View / Plain Feel / Plain Smell / Plain Hearing
- Plain View: Warrantless seizures of contraband or evidence when officers are lawfully present.
- Plain Feel: Extends Plain View; during a lawful pat-down, if an object is immediately identifiable as contraband, it may be seized.
- Plain Smell: Some contraband has distinct smells allowing seizure.
- Plain Hearing: Information overheard can be used as evidence.
Use of Dogs
- Valuable force multiplier: dogs trained to detect drugs, explosives, cadavers, etc.; assist in locating suspects and evidence.