Florida v. Rodriguez
469 U.S. 1, 83 L. Ed. 2d 165, 1984 U.S. LEXIS 159 (1984)
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Rule of Law:
The Fourth Amendment does not require that a police officer have probable cause to initiate a brief, investigatory stop of a person in an airport; rather, the stop is justified if the officer has an articulable suspicion, based on the totality of the circumstances, that the person is engaged in criminal activity.
Facts:
- At Miami International Airport, plainclothes officers Charles McGee and Detective Facchiano observed Damasco Vincente Rodriguez and two companions, Blanco and Ramirez, behaving in an unusual manner at a ticket counter.
- The officers followed the three men onto an escalator, where Blanco and Ramirez saw the officers, began speaking in lower voices, and looked back at them.
- At the top of the escalator, Blanco looked at Rodriguez and said, "Let's get out of here."
- Upon seeing the officers, Rodriguez attempted to flee by moving his legs very fast as if running in place but not covering much ground.
- When confronted, Rodriguez agreed to speak with the officers.
- Rodriguez stated he did not have an airline ticket, but Ramirez then produced a ticket with three names on it, including 'Rodriguez'.
- When asked for their names, Rodriguez identified himself as 'Rodriguez' and Blanco also initially identified himself as 'Rodriguez' before correcting his statement.
- When officers asked for consent to search his luggage, Rodriguez's companion Ramirez encouraged him to comply, and Rodriguez then handed the key to Officer McGee, who discovered cocaine inside.
Procedural Posture:
- Damasco Vincente Rodriguez was charged in a Florida state trial court with possession of cocaine with intent to distribute.
- The state trial court granted Rodriguez's motion to suppress the cocaine evidence, finding the stop violated the Fourth Amendment.
- The State of Florida, as appellant, appealed to the Florida District Court of Appeal.
- The Florida District Court of Appeal affirmed the trial court's suppression order.
- The State of Florida petitioned for a writ of certiorari, which the U.S. Supreme Court initially denied.
- Two years later, the U.S. Supreme Court granted rehearing, vacated the judgment, and remanded to the Florida District Court of Appeal for reconsideration in light of Florida v. Royer.
- On remand, the Florida District Court of Appeal again affirmed the suppression order.
- The State of Florida again petitioned the U.S. Supreme Court for a writ of certiorari.
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Issue:
Does a police officer have an articulable suspicion to justify a temporary seizure of a person for questioning in an airport when that person and his companions act furtively upon seeing the officer, attempt to flee, and provide contradictory information?
Opinions:
Majority - Per Curiam
Yes. A temporary seizure was justified by articulable suspicion under the totality of the circumstances. The initial contact between the officers and Rodriguez was a consensual encounter that did not implicate the Fourth Amendment. Assuming a seizure occurred thereafter, it was justified by articulable suspicion. This suspicion arose from the cumulative effect of several factors: the confederates' furtive speaking after sighting the officers, the statement to "get out of here," Rodriguez’s unusual attempt to flee, and the contradictory statements regarding their identities. The court also noted Officer McGee's specialized narcotics training and the fact that the encounter occurred in a major airport known as a 'source city' for narcotics. The lower court also erred by suggesting that the State must prove a defendant knew he had a right to refuse consent for the consent to be voluntary, misapplying the standard from Schneckloth v. Bustamonte.
Dissenting - Justice Stevens
No. The Court should not have granted review, as it is acting as a mere error-correcting body for a state court's fact-bound determination, a role it should not perform. The dissent argues that the Supreme Court's primary mission is not to correct every mistake made in the thousands of state tribunals, particularly on fact-intensive questions like articulable suspicion. Justice Stevens criticizes the majority for undertaking a de novo review of the trial judge's factual findings without having heard the testimony. He contends the Court's intervention is driven by a desire to punish a suspected drug courier rather than to settle an important legal question, and that the Court should defer to the state court's findings.
Analysis:
This case clarifies the 'totality of the circumstances' standard for establishing articulable suspicion in the context of airport stops. It reinforces the principle that a series of actions, each of which might be individually innocent, can collectively amount to reasonable suspicion justifying a Terry stop. The decision gives weight to an officer's specialized training and the high-crime context of the location as relevant factors in the analysis. This provides law enforcement with significant leeway in justifying brief detentions at transportation hubs and solidifies the framework for analyzing consensual encounters versus temporary seizures.
