Arrests and the Warrant Requirement

Question 1

United States v Watson

Answer 1

Facts
The events in question began on August 17, 1972, when an informant, Khoury, informed a postal inspector that the respondent, Watson, possessed a stolen credit card and proposed using it jointly. Khoury had a history of providing reliable information, including information about Watson. Acting on this tip, Khoury and Watson arranged a meeting, during which Khoury signaled the officers upon confirming Watson had additional stolen cards. Watson was arrested without a warrant at a restaurant and later gave verbal consent to search his car, where two additional stolen credit cards were found.

Issue
The primary issue was whether Watson’s warrantless arrest was constitutional and, subsequently, whether his consent to search the vehicle was voluntary and valid under the Fourth Amendment.

Holding
The Supreme Court held that Watson’s warrantless arrest did not violate the Fourth Amendment and that his consent to search the vehicle was voluntary, thereby validating the warrantless search.

Question 2

Payton v New York

Answer 2

Facts
In Payton v. New York, the Supreme Court faced the constitutionality of New York statutes that allowed police officers to enter a private residence without a warrant to arrest an individual for a felony. The facts of the case involve two separate instances where New York police entered homes without warrants to arrest suspects.
In the first instance, police broke into Theodore Payton’s apartment without a warrant, searching for evidence in connection with a murder investigation. Although Payton was not home, police seized evidence. In the second instance, police entered Obie Riddick’s home without a warrant and arrested him for armed robbery. During the arrest, they also found narcotics. Both Payton and Riddick sought to suppress the evidence obtained during these warrantless entries and arrests.

Issue
The central issue before the Supreme Court was whether the Fourth Amendment to the United States Constitution permits police officers to make a warrantless and nonconsensual entry into a suspect’s home to make a routine felony arrest.

Holding
The Supreme Court held that the Fourth Amendment, applied to the states through the Fourteenth Amendment, prohibits police from making a warrantless and nonconsensual entry into a suspect’s home to make a routine felony arrest.

Question 3

Steagald v United States

Answer 3

Facts
In early January 1978, a Drug Enforcement Administration (DEA) agent was contacted by a confidential informant who indicated the possible location of Ricky Lyons, a fugitive wanted on drug charges. Acting on information provided by the informant, DEA agents went to a residence in Atlanta, Georgia, believing Lyons could be found there. The residence, however, was occupied by Gary Steagald and Hoyt Gaultney. Upon arriving, DEA agents identified neither Steagald nor Gaultney as Lyons. Despite this, the agents proceeded to search the residence without a search warrant, based on the belief that the arrest warrant for Lyons justified the entry. During the search, the agents found and seized 43 pounds of cocaine. Steagald, who was present at the residence but not the subject of the arrest warrant, was arrested and charged with drug offenses. He moved to suppress the evidence obtained during the search, arguing it was seized in violation of the Fourth Amendment because the agents did not have a search warrant for the residence.

Issue
The legal issue in Steagald v. United States concerns whether law enforcement officers may legally search for the subject of an arrest warrant in the home of a third party without obtaining a search warrant, when no exigent circumstances or consent are present.

Holding
The Supreme Court held that, except in special situations involving exigent circumstances or consent, the entry into a home to conduct a search or make an arrest is unreasonable under the Fourth Amendment unless done pursuant to a search warrant. Therefore, the agents’ search of Steagald’s residence, based solely on an arrest warrant for another person (Lyons), violated the Fourth Amendment.

Question 4

Ashcroft v Al- Kidd

Answer 4

Facts
In the case of Ashcroft v. Al-Kidd, the respondent Abdullah al-Kidd, a U.S. citizen, was detained under a material-witness warrant authorized by then-Attorney General John Ashcroft in the wake of the September 11th attacks.
The federal officials, it is alleged, utilized the material-witness statute to detain individuals with suspected terrorist affiliations when probable cause for arrest on criminal charges was absent.
Al-Kidd was arrested in 2003 at an airport, purportedly to secure his testimony for another trial, but was never called as a witness.
He remained in federal custody for 16 days and under supervised release thereafter.
Al-Kidd later filed a Bivens action against Ashcroft and others, challenging the constitutionality of this policy and claiming his detention was a pretext for arresting him due to suspected terrorist activities.

Issue
The central legal question was whether a former Attorney General is immune from lawsuit for allegedly authorizing the detention of terrorism suspects under the guise of the material-witness statute when there might not have been probable cause to arrest them for criminal activities.
More specifically, the issue revolved around whether such actions, if proven true, violated the Fourth Amendment’s protections against unreasonable seizures.

Holding
The Supreme Court, in an opinion delivered by Justice Scalia, held that former Attorney General John Ashcroft did not violate clearly established law and was entitled to qualified immunity.
The Court ruled that the arrest and detention of a material witness pursuant to a validly obtained warrant cannot be challenged as unconstitutional solely on the basis of allegations that the arresting authority had an improper motive.