Richards v. Wisconsin Case Briefs

Case: Richards v. Wisconsin Facts: Officers obtained a warrant to enter the home of the defendant. The warrant gave no permission to the officers to enter the residence without knocking first. Due to this, officers dressed in plain clothes and pretended they were maintenance men after knocking on the defendant’s door. The defendant claimed that he saw a man in uniform behind the first officer and slammed the door, at which point officers kicked the door in, stopping the defendant and seizing drugs and money. Issue: Did the fact that the officers did not announce their true identities and purpose violate the defendant’s fourth amendment rights? Holding: No, the lack of announcement of their true purpose did not violate the defendant’s fourth amendment rights. Reasoning: The officers could have reasonably believed that by announcing their true intent, the defendant may have sought to destroy evidence. Case: Chimel v. California Facts: Officers arrived at the defendant’s home and were let in after knocking on the door by the defendant’s wife. The officers waited for a little while until the defendant arrived at his house, whereupon they showed the defendant the arrest warrant and told him they would search his house (even though they did not technically have a search warrant). As they searched the home, the officers directed the defendant’s wife to open drawers and move items so that they could be in plain view of the officers. Stolen items were seized and used at evidence at the defendant’s trial. Issue: Was the warrantless search of the defendant’s home justified under the Constitution? Holding: No, the warrantless search of the defendant’s home was not justified under the Constitution. Reasoning: At the time of the arrest it is prudent for an officer to search the person for anything dangerous or incriminating, because an arrest warrant gives the officer the right to seize anything on the defendant’s person or within his immediate surroundings. However, even when someone is arrested in their house there is no reasonable justification for searching the entirety of the house when making an arrest. Case: Arizona v. Gant Facts: Two police officers, acting on an anonymous tip that someone was selling drugs from a particular residence, went to investigate. A man answered the door and told them that the owner of the home would be back later, and the officers investigated the background of the man who had answered the door, finding that his license was suspended and a warrant for his arrest had been issued. Upon returning to the area, officers came upon two other people, whom they arrested for providing a false name and possession of drugs. When Gant came back, both of the people were secured in separate squad cars. An officer identified Gant while he was still in his vehicle and the arrest was made. After Gant was secured in a separate squad car, officers searched Gant’s car and seized weapons and drugs. Issue: Did searching Gant’s car while he was secured elsewhere violate his fourth amendment rights based on precedent set by Chimel v. California? Holding: Yes, the search in this case violated Gant’s fourth amendment rights based on the precedent set by Chimel v. California. Reasoning: In Chimel v. California, it was ruled that searches incident to an arrest may only be conducted on the arrestee’s person or within their immediate reach in order to ensure the safety of the officers and the general public, as well as to ensure that no evidence is destroyed. Since the search occurred out of Gant’s immediate reach while he was safely secured in a squad car, the evidence was no good. Case: Knowles v. Iowa Facts: Knowles was stopped by police for going 43 in a 25 mph zone. Officers could have technically made an arrest but simply gave Knowles a citation: however, they conducted a search of Knowles’s car and discovered a pot pipe and marijuana. Issue: Since the officers did not actually make an arrest, was the search “good” under the search incident to arrest rule—were Knowles’s fourth amendment rights violated? Holding: No, the search was not “good,” and it violated Knowles’s fourth amendment rights. Reasoning: Although officer safety is still a concern in this case of a routine traffic stop, it is not as much of a concern as it would be had the officers decided to make an arrest. In this case, the only evidence that the officers had required in order to issue the citation was evidence of speeding, which was obtained before the actual stop even took place. Case: U.S. v. Whren Facts: Officers were patrolling in an unmarked car in an area which was known for drug trafficking. They noticed a car with temporary license plates and fairly young people driving, which had stopped at a stop sign and stayed there for an oddly long time. Officers made a 180 degree turn to pursue the suspicious vehicle and upon doing so, the vehicle sped off to the right without signaling. The officers made a stop of the vehicle once they caught up and observed what appeared to be crack cocaine in the hands of one of the occupants. After this, the defendants were arrested and the drug paraphernalia were seized. Issue: Did the arrest and subsequent seizure of drugs violate the defendant’s fourth amendment rights? Was the initial traffic stop justified? Holding: The officers did not violate the defendant’s fourth amendment rights, and the traffic stop and subsequent seizure of drugs was justified. Reasoning: The precedent set by Robinson states that officers are allowed to make a search subsequent to a traffic stop as long as 1. The traffic stop was objectively reasonable and 2. The subsequent search was objectively reasonable under the circumstances. Also under consideration was the state of mind of the officer: did the officers make the stop because they were expecting to make a “drug bust” or did they simply make the traffic stop for the sake of making a traffic stop and then notice the drugs in the car? This question was deemed irrelevant, as regardless of the officer’s intent a traffic violation was made, and drugs were subsequently in plain view of the officers. Case: Schneckloth v. Bustamonte Facts: An officer stopped a vehicle when he noticed that one of its headlights, as well as the license light, were burned out. There were six men in the car, and only one of them was able to produce identification. The officer asked the men to exit the vehicle and called for backup, whereupon he asked to search the car: the brother of the owner replied, “Go ahead.” The officer found three stolen checks in the trunk of the car. Issue: Was the man who gave consent to search aware of his rights to refuse consent to search the vehicle—were his fourth or fourteenth amendment rights violated? Holding: His rights were not violated—he was asked if it was alright to search the car, with no undue pressure put on him to consent to the search. Reasoning: In this case, it was important to look at all the factors within the situation as far as the man’s consent was concerned. Although officers never explicitly informed the man of his right to refuse a search, the situation remained friendly and the court determined that no undue pressure had been placed upon the man who had agreed to the search. Case: Illinois v. Rodriguez Facts: Police arrived at a home which they had been called to regarding the assault of a woman by the defendant. Police gained access to the defendant’s room by way of the victim unlocking his door, and proceeded to arrest him, finding a large amount of drugs in plain view. No warrants were obtained for any of these proceedings. Issue: Was the other party in this case (the victim) able to legally consent to a search in leu of the defendant? Were the defendant’s fourteenth amendment rights violated? Holding: The defendant’s fourteenth amendment rights were not violated: the search was good, and the victim was a resident of that home. Reasoning: The victim in this case lived in the same building as the defendant and was able to provide “third party” consent. With this holding, however, the court advised that officers assess all the factors in the situation when determining if someone is legally able to consent to a search in place of another: do they really have partial ownership of what is to be searched? Case: Wyoming v. Houghton Facts: An officer pulled over a car for going over the speed limit, as well as for having a broken light. While speaking with one of the occupants, the officer saw a needle in his shirt pocket. The officer asked the man to exit the vehicle and place the needle on the hood of the car: upon asking the man what exactly the needle was for, he replied that he used it to shoot up drugs. The officers then searched the vehicle and the purses of the other passengers, discovering more drugs. Issue: Was the search of the purses “fruit of the poisonous tree?” Holding: No, the search of the purses was not “fruit of the poisonous tree.” Reasoning: The officers already knew that the vehicle contained illegal substances: it would not be a stretch to assume that any bags/purses/etc. within the car being searched may contain drugs as well.