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View Full Version : SCOTUS: An Arrest Barred By State Law Is Still OK Under The 4th Amendment


DaJudge
April 23rd, 2008, 02:51 PM
VIRGINIA v. MOORE (No. 06-1082)
Web-accessible at:
http://www.law.cornell.edu/supct/html/06-1082.ZS.html (http://www.law.cornell.edu/supct/html/06-1082.ZS.html)
Argued: January 14, 2008 -- Decided: April 23, 2008 Opinion author: Scalia
========================================================

Rather than issuing the summons required by Virginia law, police arrested
respondent Moore for the misdemeanor of driving on a suspended license. A
search incident to the arrest yielded crack cocaine, and Moore was tried on
drug charges. The trial court declined to suppress the evidence on Fourth
Amendment grounds. Moore was convicted. Ultimately, the Virginia Supreme
Court reversed, reasoning that the search violated the Fourth Amendment
because the arresting officers should have issued a citation under state
law, and the Fourth Amendment does not permit search incident to citation.

Held: The police did not violate the Fourth Amendment when they made an
arrest that was based on probable cause but prohibited by state law, or
when they performed a search incident to the arrest. Pp. 3-13.

(a) Because the founding era's statutes and common law do not support
Moore's view that the Fourth Amendment was intended to incorporate
statutes, this is "not a case in which the claimant can point to a 'clear
answer [that] existed in 1791 and has been generally adhered to by the
traditions of our society ever since,' " Atwater v. Lago Vista, 532 U. S.
318 . Pp. 3-5.

(b) Where history provides no conclusive answer, this Court has analyzed a
search or seizure in light of traditional reasonableness standards "by
assessing, on the one hand, the degree to which it intrudes upon an
individual's privacy and, on the other, the degree to which it is needed for
the promotion of legitimate governmental interests." Wyoming v. Houghton,
526 U. S. 295 . Applying that methodology, this Court has held that when
an officer has probable cause to believe a person committed even a minor
crime, the arrest is constitutionally reasonable. Atwater, supra, at 354.

This Court's decisions counsel against changing the calculus when a State
chooses to protect privacy beyond the level required by the Fourth
Amendment. See, e.g., Whren v. United States, 517 U. S. 35 . United
States v. Di Re, 332 U. S. 581 , distinguished. Pp. 6-8.

(c) The Court adheres to this approach because an arrest based on
probable cause serves interests that justify seizure.

Arrest ensures that a suspect appears to answer charges and does not
continue a crime, and it safeguards evidence and enables officers to
conduct an in-custody investigation.

A State's choice of a more restrictive search-and-seizure policy does not
render less restrictive ones unreasonable, and hence unconstitutional. While
States are free to require their officers to engage in nuanced
determinations of the need for arrest as a matter of their own law, the
Fourth Amendment should reflect administrable bright-line rules.

Incorporating state arrest rules into the Constitution would make Fourth
Amendment protections as complex as the underlying state law, and
variable from place to place and time to time. Pp. 8-11.

(d) The Court rejects Moore's argument that even if the Constitution
allowed his arrest, it did not allow the arresting officers to search him.
Officers may perform searches incident to constitutionally permissible
arrests in order to ensure their safety and safeguard evidence. United
States v. Robinson,414 U. S. 218 . While officers issuing citations do not
face the same danger, and thus do not have the same authority to search,
Knowles v. Iowa, 525 U. S. 113 , theofficers arrested Moore, and therefore
faced the risks that are "an adequate basis for treating all custodial arrests
alike for purposes of search justification," Robinson, supra, at 235. Pp. 11-
13.

272 Va. 717, 636 S. E. 2d 395, reversed and remanded.

Scalia, J., delivered the opinion of the Court, in which Roberts, C. J., and
Stevens, Kennedy, Souter, Thomas, Breyer, and Alito, JJ., joined. Ginsburg,
J., filed an opinion concurring in the judgment.

CannonBall
April 24th, 2008, 09:32 AM
On the surface I disagree with this, but I don?t think I know enough to really make an educated statement. The state law said he couldn?t be prosecuted and he was unlawfully searched, but NO! Oh well, I suppose you can?t comment.
-Nate

DaJudge
April 24th, 2008, 10:17 AM
On the surface I disagree with this, but I don?t think I know enough to really make an educated statement. The state law said he couldn?t be prosecuted and he was unlawfully searched, but NO! Oh well, I suppose you can?t comment.
-Nate
Actually, I can comment as the case is over now.

The United States is a Federal Republic. We have Federal Law on the one hand and State (and Territorial/Commonwealth) statutes on the other. These codes exist side-by-side with the Federal laws having 'higher' authority due to the Supremecy clause of the US Constitution. The Supreme Court has held that Federal constitutional protections apply to all of us and that each state can enact greater protections for their residents if they wish to. This decision basically reiterates that. The VA Supreme Court threw out the conviction on the grounds that the arrest violated the 4th A of the US Constitution. SCOTUS said, "No, it didn't. If you want to throw it out, you have to do it based on VA law, NOT Federal law."

Oscar
April 24th, 2008, 10:18 AM
My very simplistic view is this. When in the AF my Tech data (rules or law) when in conflict with aircrew rules (flight manuals) mine were the higher authority. That sounds like what happened here. A conflict between the law and the constitution wins. Right?

CannonBall
April 24th, 2008, 10:35 AM
der, I'm sorry, I'm out of it today but they upheld the state law? I'm ok with that, and the fact that ginsburg reluctantly agreed to the rest of the court makes me generally think it's good... I typically think the opposite of her opinion is the better choice.
-Nate

edit: honestly my reading comprehension is just terrible today, I think if I'd taken that trick quiz today I'd get like a 5/11. Oh well, sorry to ask for a spoon feeding on this one.

Yota
April 24th, 2008, 12:16 PM
I appreciate it when the court gives at least a shout out to common law as it was understood in the 18th century and to the intent of the founders, as in (a) and (b) above. I guess they did that in response to an argument by Moore but that eye to the original intent is what gives an opinion like this a "strict construction" feel and that, to me, is the right place to start interpreting the constitution.