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Arkansas v. Sullivan

Supreme Court of the United States
532 US 769, 149 L. Ed. 2d 994, 2001 U.S. LEXIS 4118 (2001)
ELI5:

Rule of Law:

Under the Fourth Amendment, a police officer's subjective motivation for making an arrest is irrelevant as long as the arrest is objectively justified by probable cause that a crime has been committed.


Facts:

  • In November 1998, Officer Joe Taylor stopped Kenneth Sullivan for speeding and for having an improperly tinted windshield.
  • Upon seeing Sullivan's license, Officer Taylor recognized his name from 'intelligence...regarding narcotics.'
  • While Sullivan was unsuccessfully looking for his registration and insurance papers, Taylor noticed a rusted roofing hatchet on the vehicle's floorboard.
  • Taylor arrested Sullivan for speeding, driving without registration and insurance, improper window tinting, and carrying a weapon.
  • After another officer placed Sullivan in a squad car, Taylor conducted an inventory search of Sullivan's vehicle.
  • During the search, Taylor discovered a bag under the armrest containing a substance believed to be methamphetamine and drug paraphernalia.

Procedural Posture:

  • Sullivan was charged in an Arkansas state trial court with drug offenses, unlawful possession of a weapon, and speeding.
  • Sullivan filed a motion to suppress the evidence seized from his vehicle, arguing his arrest was a pretext for a search.
  • The trial court granted the motion to suppress.
  • The State of Arkansas filed an interlocutory appeal to the Arkansas Supreme Court, the state's highest court.
  • The Arkansas Supreme Court affirmed the trial court's decision to suppress the evidence.
  • The State of Arkansas petitioned for rehearing, which the Arkansas Supreme Court denied.
  • The State of Arkansas then petitioned the U.S. Supreme Court for a writ of certiorari.

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Issue:

Does a police officer's subjectively pretextual motive for an arrest violate the Fourth Amendment if the arrest is objectively supported by probable cause for a minor criminal offense?


Opinions:

Majority - Per Curiam

No. An officer's subjective motivation for making an arrest does not invalidate the arrest under the Fourth Amendment as long as the arrest is supported by probable cause. The Court's precedent in Whren v. United States holds that subjective intentions play no role in an ordinary, probable-cause Fourth Amendment analysis. The fact that Whren involved a traffic stop rather than a custodial arrest is immaterial, as Whren itself relied on cases involving pretextual traffic-violation arrests. Furthermore, a state supreme court cannot interpret the U.S. Constitution to provide greater protections than the U.S. Supreme Court's own precedents. While a state is free to impose greater restrictions on police under its own state law, it may not do so as a matter of federal constitutional law.


Concurring - Justice Ginsburg

No. Based on the Court's current case law, particularly Atwater v. Lago Vista and Whren v. United States, exercises of official discretion like this are not limited by the Fourth Amendment. While joining the Court's opinion, this concurrence acknowledges the Arkansas Supreme Court's concern about granting police disturbing discretion to intrude on liberty and privacy. If experience demonstrates an 'epidemic of unnecessary minor-offense arrests,' the Court should be willing to reconsider its recent precedent.



Analysis:

This decision solidifies the purely objective standard for Fourth Amendment probable cause analysis established in Whren v. United States. It confirms that an officer's pretextual motive is irrelevant not only for traffic stops but also for subsequent custodial arrests, provided there is objective justification for the action. This ruling gives law enforcement significant discretion, allowing officers to use minor, observable violations as a basis to stop and arrest individuals they may subjectively suspect of more serious, non-observable crimes. The case also serves as a strong reminder of federal judicial supremacy, clarifying that state courts cannot interpret the U.S. Constitution more broadly than the Supreme Court itself.

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