Davis v. Mississippi
394 U.S. 721 (1969)
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Rule of Law:
The Fourth Amendment's exclusionary rule applies to physical evidence, including fingerprints, obtained from a person during a seizure or detention that is not supported by a warrant or probable cause.
Facts:
- On December 2, 1965, a rape occurred at a home in Meridian, Mississippi.
- The victim could only describe her attacker as a 'Negro youth,' and the only other evidence police had were finger and palm prints found on a window sill.
- Beginning December 3, police conducted a dragnet, detaining at least 24 Black youths without warrants for questioning and fingerprinting.
- The petitioner, a 14-year-old youth, was taken to police headquarters on December 3, where he was fingerprinted and questioned before being released.
- Between December 3 and 7, police interrogated the petitioner on several more occasions.
- On December 12, police arrested the petitioner without a warrant or probable cause, drove him 90 miles to another city, and jailed him overnight.
- On December 14, while still in custody from the December 12 arrest, police fingerprinted the petitioner for a second time.
- The FBI determined that the fingerprints taken on December 14 matched the prints recovered from the crime scene window.
Procedural Posture:
- Petitioner was tried for rape in the Circuit Court of Lauderdale County, Mississippi, a state trial court.
- At trial, the court admitted fingerprint evidence over petitioner's objection that it was the product of an unlawful detention.
- The jury convicted the petitioner, and he was sentenced to life imprisonment.
- Petitioner appealed the conviction to the Mississippi Supreme Court, the state's highest court.
- The Mississippi Supreme Court affirmed the conviction, holding that the fingerprint evidence was admissible.
- The Supreme Court of the United States granted the petitioner's petition for a writ of certiorari.
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Issue:
Does the Fourth Amendment prohibit the admission of fingerprint evidence obtained from a suspect during a detention that was conducted without a warrant or probable cause?
Opinions:
Majority - Mr. Justice Brennan
Yes, the Fourth Amendment prohibits the admission of such evidence. The exclusionary rule, which bars the use of evidence obtained through unconstitutional searches and seizures, applies to all types of evidence, including fingerprints. The Court rejected the argument that the trustworthiness of fingerprint evidence creates an exception to the rule. Both the initial detention on December 3 and the subsequent arrest on December 12 were seizures under the Fourth Amendment, and the state conceded they were made without probable cause. Therefore, the fingerprints obtained during the illegal detention on December 14 were the product of an unconstitutional seizure and must be suppressed. The Court also found the earlier December 3 fingerprinting to be invalid, reasoning that investigatory detentions are still 'seizures' that require Fourth Amendment justification, which was absent here.
Concurring - Mr. Justice Harlan
Yes, the fingerprint evidence must be excluded in this case. While agreeing with the Court's conclusion regarding the unconstitutionality of the dragnet procedures used here, I write separately to express reservation with the majority's sweeping dictum that a warrant would always be required for compelled fingerprinting. There may be narrowly defined circumstances, short of a dragnet, where compelled fingerprinting without a warrant could satisfy the Fourth Amendment, and that question should remain open.
Dissenting - Mr. Justice Black
No, the fingerprint evidence should not be excluded. The Court is once again unnecessarily expanding the scope of the Fourth Amendment and the exclusionary rule, which hinders the administration of criminal justice. The fingerprints were the clinching evidence in a brutal rape case. The Court should re-evaluate the Fourth Amendment and 'cut it down to its intended size' to help make cities safer, rather than reversing convictions on such grounds.
Dissenting - Mr. Justice Stewart
No, the exclusionary rule does not require the reversal of this conviction. Fingerprints are not 'evidence' in the same way as a coerced confession or illegally seized weapon; they are an inherent and unchangeable physical characteristic of a person. Unlike tainted evidence, fingerprints can be identically reproduced and lawfully obtained at any subsequent trial. Reversing this conviction is a 'useless gesture' because the state now has probable cause to detain the petitioner, lawfully obtain his fingerprints, and secure a new conviction.
Analysis:
This decision firmly establishes that the Fourth Amendment's exclusionary rule applies to physical evidence like fingerprints, rejecting any exception for evidence deemed 'trustworthy.' It clarifies that investigative detentions, even if not formal arrests, are 'seizures' that require constitutional justification, which generally means probable cause. By invalidating the police's dragnet tactics, the case significantly curbed the ability of law enforcement to round up individuals for investigative purposes without particularized suspicion. The majority's opinion also left the door open for future consideration of whether a court order based on less than probable cause could authorize fingerprinting under narrowly defined circumstances.
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