Hedgepeth Ex Rel. Hedgepeth v. Washington Metropolitan Area Transit Authority
363 U.S. App. D.C. 260, 386 F.3d 1148, 2004 U.S. App. LEXIS 22230 (2004)
Rule of Law:
An arrest for a minor criminal offense does not violate the Fourth Amendment so long as the officer has probable cause. A policy that treats juveniles differently from adults by subjecting them to arrest for such an offense, while adults only receive a citation, does not violate the equal protection component of the Fifth Amendment if it is rationally related to a legitimate government interest.
Facts:
- The Washington Metropolitan Area Transit Authority (WMATA) received complaints about student misbehavior and implemented a week-long "zero-tolerance" policy against violating ordinances, including one that prohibited eating in Metrorail stations.
- Under District of Columbia law at the time, adults could be issued a citation for violating the ordinance, but the law did not authorize citations for non-traffic offenses committed by juveniles.
- The combined effect of WMATA's policy and D.C. law was that juveniles caught eating in the Metro would be arrested, while adults would only receive a citation.
- On October 23, 2000, twelve-year-old Ansche Hedgepeth was on her way home from school when she entered the Tenleytown Metrorail station.
- While waiting for a friend, Hedgepeth ate a single french fry from a take-out bag she was holding.
- A plainclothes Metro Transit Police officer observed the act and arrested Hedgepeth for eating in the station.
- Hedgepeth was handcuffed, searched, had her shoelaces removed, and was transported to a juvenile processing center.
- She was booked, fingerprinted, and detained for approximately three hours before being released to her mother.
Procedural Posture:
- Tracey Hedgepeth, as next friend to her daughter Ansche, filed a lawsuit under 42 U.S.C. § 1983 in the U.S. District Court for the District of Columbia against WMATA, its General Manager, the arresting officer, and the District of Columbia.
- The complaint alleged that Ansche's arrest violated the Fourth Amendment's prohibition on unreasonable seizures and the equal protection component of the Fifth Amendment.
- The parties filed cross-motions for summary judgment.
- The district court granted summary judgment in favor of the defendants, holding that the arrest was constitutional.
- Hedgepeth, as appellant, appealed the district court's decision to the U.S. Court of Appeals for the D.C. Circuit.
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Issue:
Does a policy that requires the custodial arrest of a juvenile for a minor offense for which an adult would only receive a citation violate the Fourth Amendment's protection against unreasonable seizures or the Fifth Amendment's equal protection component, when the arrest is supported by probable cause?
Opinions:
Majority - Circuit Judge Roberts
No. A policy requiring the custodial arrest of a juvenile for a minor offense supported by probable cause, even when adults receive only citations, violates neither the Fourth nor the Fifth Amendment. Regarding the Fifth Amendment equal protection claim, classifications based on youth are not suspect or quasi-suspect and do not trigger heightened scrutiny. The right at issue is not a fundamental right to freedom from restraint, but rather the right to freedom of movement when there is probable cause for arrest, which the law does not recognize as fundamental. Therefore, the policy is subject to rational basis review. The District's no-citation policy for minors is rationally related to the legitimate government interest of promoting parental awareness and involvement when a child commits a delinquent act, as an arrest ensures parental notification in a way a citation might not. Regarding the Fourth Amendment claim, the Supreme Court's decision in Atwater v. City of Lago Vista is controlling. Atwater established that if an officer has probable cause to believe an individual has committed even a very minor criminal offense, an arrest of that individual does not violate the Fourth Amendment. This bright-line rule applies whether the decision to arrest is made by an officer in the field exercising discretion or is mandated by a pre-existing, non-discretionary policy. The court cannot inquire into the reasonableness of the decision to arrest when probable cause exists, only the reasonableness of the manner in which the arrest is carried out.
Analysis:
This case solidifies the broad authority of law enforcement to make arrests for even the most minor offenses, extending the Supreme Court's holding in Atwater to scenarios involving mandatory, non-discretionary arrest policies. It also reinforces that age-based classifications, particularly those concerning juveniles, receive the lowest level of judicial scrutiny (rational basis review), granting significant deference to legislative judgments about how to treat minors differently within the justice system. The decision underscores that even policies considered 'foolish' or disproportionate by the public and even the court itself can be constitutional. Consequently, challenges to harsh arrest policies for minor infractions are more likely to find success through political and legislative reform than through judicial intervention on Fourth or Fifth Amendment grounds.
