United States v. Watson
423 U.S. 411 (1976)
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Rule of Law:
The Fourth Amendment does not require a warrant for a felony arrest made in a public place, so long as the arresting officer has probable cause to believe the suspect has committed or is committing a felony. An otherwise valid warrantless public arrest is not invalidated simply because the officers had adequate time and opportunity to obtain a warrant.
Facts:
- An informant, Khoury, who had previously provided reliable information to a postal inspector, reported that respondent Watson possessed a stolen credit card.
- Khoury delivered the stolen credit card to the postal inspector and agreed to arrange a future meeting with Watson.
- A few days later, Watson and Khoury met at a restaurant under the surveillance of postal inspectors.
- At the restaurant, Khoury gave a pre-arranged signal to the inspectors, indicating that Watson had additional stolen credit cards in his possession.
- The postal inspectors then entered the restaurant and arrested Watson without a warrant.
- After being read his Miranda rights on the street, Watson consented to a search of his nearby car.
- The inspectors used keys provided by Watson to enter the car and found two stolen credit cards under the floor mat.
Procedural Posture:
- Watson was indicted in U.S. District Court on charges of possessing stolen mail.
- Prior to trial, Watson filed a motion to suppress the credit cards found in his car, arguing his arrest was illegal for lack of a warrant and his consent to search was involuntary.
- The District Court (trial court) denied the motion to suppress.
- Following a trial, Watson was convicted on two counts of possessing stolen mail.
- Watson (as appellant) appealed to the U.S. Court of Appeals for the Ninth Circuit.
- The Court of Appeals reversed the conviction, holding that the warrantless arrest was unconstitutional because officers had time to get a warrant and that the subsequent consent to search was therefore coerced.
- The United States (as petitioner) sought and was granted a writ of certiorari by the U.S. Supreme Court.
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Issue:
Does the Fourth Amendment prohibit a law enforcement officer from making a warrantless felony arrest in a public place, based on probable cause, when there was adequate opportunity to obtain an arrest warrant?
Opinions:
Majority - Mr. Justice White
No, the Fourth Amendment does not prohibit a warrantless felony arrest in a public place based on probable cause, even if officers had time to obtain a warrant. Federal statutes and the common-law rule, which was well-established at the time the Fourth Amendment was ratified, permit peace officers to make warrantless arrests in public for felonies, provided they have reasonable grounds or probable cause. The Court's precedents have consistently assumed the validity of this rule, focusing the inquiry on whether probable cause existed, not on whether a warrant was obtained. To impose a warrant requirement for public arrests would be an intolerable handicap on law enforcement and would encumber prosecutions with endless litigation over whether exigent circumstances existed. Because Watson's arrest was constitutional, his subsequent consent to the car search was not tainted by an illegal arrest, and the consent was voluntary under the totality of the circumstances.
Concurrence - Mr. Justice Powell
No, the warrantless arrest was permissible. Although logic might suggest that arrests should be subject to the same warrant requirement as searches, history and experience dictate a different result. The common law has long sanctioned warrantless felony arrests, a practice that was unimpeached when the Fourth Amendment was adopted and has been consistently approved by legislatures and courts since. A contrary ruling would create a new constitutional rule that could severely hamper police practices, such as continuing an investigation after probable cause is established. Law enforcement has developed procedures based on the assumption that warrantless public arrests based on probable cause are valid, and there is no compelling reason to overturn this long-standing practice.
Concurrence - Mr. Justice Stewart
No, the arrest did not violate the Fourth Amendment. The arrest was made upon probable cause in a public place in broad daylight. However, this case does not decide whether or under what circumstances an officer must obtain a warrant before lawfully entering a private place to effect an arrest, a question which remains open.
Dissenting - Mr. Justice Marshall
Yes, a warrantless public arrest based on probable cause violates the Fourth Amendment when there are no exigent circumstances. The Court's reliance on the common-law rule is flawed because the definition of a 'felony' has expanded dramatically since the 18th century, meaning the exception now swallows the rule. The Fourth Amendment's protection of 'persons' should be at least as robust as its protection of 'houses, papers, and effects,' which generally requires a warrant for searches. An arrest is a profound invasion of privacy, and the protection of a neutral magistrate's pre-arrest review of probable cause is just as critical for seizures of persons as it is for searches of property. The practical burdens of a warrant requirement are overstated, as demonstrated by the FBI's standard practice of obtaining warrants before making arrests.
Analysis:
This decision establishes a clear constitutional line between searches and seizures of persons in public. While the Court had previously established a strong preference for warrants in the context of searches, Watson holds that this preference does not translate into a constitutional requirement for arrests made in public. The ruling provides law enforcement with a clear, bright-line rule, avoiding a case-by-case analysis of whether 'exigent circumstances' justified the lack of a warrant. However, the decision also significantly limits the role of judicial pre-screening for seizures of individuals, placing greater reliance on the officer's on-the-spot probable cause determination. The case also critically leaves open the question of whether a warrant is required to arrest a suspect within their own home, an issue the Court would later address in Payton v. New York.
