State v. Williams
490 So. 2d 255 (1986)
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Rule of Law:
A prisoner on furlough remains in the constructive custody of the state and has a diminished expectation of privacy, meaning law enforcement does not need probable cause to detain them for questioning.
Facts:
- Dobie Gillis Williams was serving a sentence for attempted simple burglary and was on a five-day furlough from Camp Beauregard.
- On the night of July 7, 1984, Williams cut a screen and entered the home of Sonja Knippers through the bathroom window.
- Williams was staying at his grandfather's home, located approximately 2000 feet from the Knippers' residence.
- Sonja Knippers went to her bathroom and discovered Williams, who had his pants off, hiding behind the door.
- When Knippers screamed, Williams locked the door and stabbed her eight times with a knife.
- Sonja's husband, Charles Knippers, was awakened by the noise but was unable to break down the locked bathroom door.
- Sonja Knippers eventually opened the door but collapsed and bled to death shortly thereafter.
- Williams escaped through the bathroom window, leaving the knife in the yard and hiding his shirt under his grandfather's porch.
Procedural Posture:
- Dobie Gillis Williams was indicted for first-degree murder by a Sabine Parish Grand Jury.
- The defendant's Motion for a Change of Venue was granted, transferring the case to the 35th Judicial District Court in Grant Parish (trial court).
- The defendant filed a Motion to Suppress his confession, which the trial court denied.
- Following a trial, a jury found Williams guilty of first-degree murder.
- In the subsequent sentencing phase, the jury recommended the death penalty.
- Williams appealed his conviction and sentence directly to the Supreme Court of Louisiana.
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Issue:
Does detaining a prisoner on furlough for questioning, without probable cause, violate their constitutional protection against unreasonable seizures, thereby rendering a subsequent confession inadmissible?
Opinions:
Majority - Justice Blanche
No. Detaining a prisoner on furlough for questioning without probable cause does not violate their constitutional rights because such individuals have a significantly diminished expectation of privacy. Prisoners, by virtue of their incarceration, have decreased expectations of privacy. The court analogized this case to State v. Patrick, which held that a work-release inmate has no reasonable expectation of privacy requiring probable cause for a search. A person on furlough, like a work-release inmate, enjoys a 'conditional or qualified' liberty and remains in the 'constructive custody of the state.' This status is not altered by the longer duration of a furlough compared to daily work-release, and therefore, the defendant had no reasonable expectation of privacy that was violated. Consequently, the detention was not illegal, and the confession was admissible.
Concurring - Justice Lemmon
No. The ultimate constitutional question is not whether the defendant had an expectation of privacy, but whether the police conduct was reasonable under the totality of the circumstances. In this case, the police conduct was reasonable. The officers knew that a murder had been committed by a Black man who escaped through a window; that Williams had a prior burglary conviction and was on furlough nearby; that he lived within 2,000 feet of the crime scene; and that he had fresh scratches and a puncture wound consistent with the crime. These specific, articulable facts made the police's decision to detain and question Williams a reasonable one, irrespective of a broad rule about the privacy rights of furloughed inmates.
Analysis:
This decision clarifies and extends the legal principle that prisoners have a diminished expectation of privacy, applying it specifically to those on furlough. By placing furloughed individuals in the same legal category as work-release inmates, the court gives law enforcement greater authority to detain and investigate them without meeting the probable cause standard required for ordinary citizens. This ruling establishes a clear precedent that an individual's status as a prisoner on conditional release significantly lowers their Fourth Amendment protections. It will likely impact future cases involving crimes committed by individuals who are not physically incarcerated but remain under the legal custody of the state.
