Hayes v. Florida
470 U.S. 811 (1985)
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Rule of Law:
The Fourth Amendment does not permit police to transport a suspect to a police station for fingerprinting without the suspect's consent, probable cause, or prior judicial authorization, as such a seizure is sufficiently analogous to a formal arrest to require probable cause.
Facts:
- A series of burglary-rapes occurred in Punta Gorda, Florida, in 1980.
- Police discovered latent fingerprints on a doorknob at one of the crime scenes, which they believed belonged to the assailant.
- Investigators identified petitioner Hayes as a principal suspect after interviewing 30 to 40 men who fit a general description of the attacker.
- Police officers went to Hayes's home without a warrant to obtain his fingerprints.
- When Hayes expressed reluctance to voluntarily go to the station for fingerprinting, an officer on his front porch threatened to arrest him if he did not cooperate.
- In response to the threat of arrest, Hayes stated he would rather go with the officers than be arrested.
- While on the porch, officers also seized a pair of herringbone pattern tennis shoes that were in plain view.
- Hayes was then taken to the station house where his fingerprints were taken and found to match those from the crime scene.
Procedural Posture:
- Hayes was charged with burglary and sexual battery in a Florida trial court.
- Hayes filed a pretrial motion to suppress the fingerprint evidence, which the trial court denied.
- Following a trial, Hayes was convicted of burglary and sexual battery.
- Hayes, as appellant, appealed his conviction to the District Court of Appeal of Florida, Second District.
- The District Court of Appeal, with the State as appellee, affirmed the conviction, holding that transporting a suspect for fingerprinting was permissible on reasonable suspicion.
- The Florida Supreme Court denied review.
- The United States Supreme Court granted Hayes's petition for a writ of certiorari.
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Issue:
Does the Fourth Amendment permit police, without a warrant or probable cause, to involuntarily transport a suspect from his home to the police station for the purpose of obtaining fingerprints?
Opinions:
Majority - Justice White
No. The involuntary transportation of a suspect from his home to a police station for investigative purposes without probable cause or a warrant violates the Fourth Amendment. The Court reaffirmed its holding in Davis v. Mississippi, stating that such seizures are sufficiently like an arrest to require the traditional justification of probable cause. The line between a permissible investigatory stop and an unconstitutional seizure is crossed when police, without probable cause or judicial authorization, forcibly remove a person from his home or another place he is entitled to be and transport him to the police station for detention, however brief. The Court distinguished this situation from a brief detention in the field for fingerprinting, which might be permissible under reasonable suspicion, but held that removal to the station house triggers the full protections of the Fourth Amendment.
Concurring - Justice Brennan
No. The judgment must be reversed because this case is factually indistinguishable from Davis v. Mississippi, where the Court held that detaining a suspect and transporting him to the station for fingerprinting without probable cause or a warrant was an unreasonable seizure. However, the majority goes too far by speculating on the constitutionality of on-site, in-the-field fingerprinting based on reasonable suspicion. This issue was not before the Court, the record contains no facts to analyze it under Terry v. Ohio, and the Court's discussion amounts to an inappropriate advisory opinion on a hypothetical police practice.
Analysis:
This decision solidifies the constitutional line between an investigative stop under Terry v. Ohio and a de facto arrest. It establishes that transporting a suspect to the police station for investigative purposes is a significant intrusion on liberty that cannot be justified by mere reasonable suspicion. By reaffirming Davis v. Mississippi, the Court reinforces the principle that the station house is a critical threshold; once crossed, the full protections of probable cause are required. The opinion's discussion of potential exceptions, such as brief field fingerprinting or judicially authorized seizures on less than probable cause, left the door open for future legal developments in investigative detentions while clearly prohibiting the specific police conduct in this case.
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