Brief Fact Summary. A mother was taken into custody for violation of Texas’ strict seatbelt law. She subsequently sued for Fourth Amendment violations.
Synopsis of Rule of Law. “The standard of probable cause ‘applies to all arrests, without the need to balance the interests and circumstances involved in particular situations.’”
The officer was accordingly authorized (not required, but authorized) to make a custodial arrest without balancing costs and benefits or determining whether or not plaintiff's arrest was in some sense necessary.View Full Point of Law
Issue. “[W]hether the Fourth Amendment forbids a warrantless arrest for a minor criminal offense, such as a misdemeanor seatbelt violation punishable only by a fine.”
Held. No. The Supreme Court noted that the respondent wanted a new rule “one not necessarily requiring violent breach of the peace, but nonetheless forbidding custodial arrest, even upon probable cause, when conviction could not ultimately carry any jail time and when the government shows no compelling need for immediate detention.” The court was unwilling to do this, noting “complications arise the moment we begin to think about the possible applications of the several criteria [the respondent] proposes for drawing a line between minor crimes with limited arrest authority and others not so restricted.” Citing several examples, the court concluded by noting that the respondent’s rule would “place police in an almost impossible spot” and “guarantee increased litigation over many of the arrests that would occur.” Given that it would cause more troubles than it would solve, the court refused to adopt the rule, and held arrests were permissible under all circumstances of criminal act
Dissent. The dissent was dissatisfied with “a rule which deems a full custodial arrest to be reasonable in every circumstance.” The argument was for the standard articulated in Terry v. Ohio: “specific and articulable facts which, taken together with rational inferences from those facts, reasonably warrant [the additional] intrusion” of arrest.
Discussion. “If an officer has probable cause to believe that an individual has committed even a very minor criminal offense, he may, without violating the Fourth Amendment, arrest the offender.”