Beck v. Ohio

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Beck v. Ohio
Seal of the United States Supreme Court.svg
Argued October 15, 1964
Decided November 23, 1964
Full case nameBeck v Ohio
Citations379 U.S. 89 ( more )
85 S. Ct. 223; 13 L. Ed. 2d 142
Holding
No probable cause for petitioner's arrest having been shown, the arrest, and therefore necessarily the search for and seizure of the slips incident thereto, were invalid under the Fourth and Fourteenth Amendments
Court membership
Chief Justice
Earl Warren
Associate Justices
Hugo Black  · William O. Douglas
Tom C. Clark  · John M. Harlan II
William J. Brennan Jr.  · Potter Stewart
Byron White  · Arthur Goldberg
Case opinions
MajorityStewart, joined by Warren, Douglas, Brennan, White, Goldberg
DissentClark, joined by Black
DissentHarlan
Laws applied
U.S. Const. amend. IV

Beck v. Ohio, 379 U.S. 89 (1964), is a United States Supreme Court decision concerning evidence obtained as part of an unlawful arrest. Reversing the Ohio Supreme Court's decision, the U.S. Supreme Court held that Ohio police arrested defendant without probable cause, so the criminally-punishable evidence found on his person during an incidental search was inadmissible. Accordingly, the U.S. Supreme Court vacated defendant's conviction.

Contents

Facts

Receiving unspecified "information" and "reports" concerning William Beck and his current whereabouts, policeman in Cleveland, Ohio stopped him in his automobile and placed him under arrest without a warrant on November 10, 1961, for "a clearing house operation, scheme of chance." [1] As incidental to arrest, they searched, firstly, his car and found nothing noteworthy. At the police station, however, they searched his person and discovered, "beneath the sock of his leg," an envelope containing a number of clearing house slips, a then-illegal possession in Ohio for which he was charged in Cleveland Municipal Court.

Beck filed a motion to suppress the slips, arguing that they were seized in violation of the Fourth and Fourteenth Amendments, but the Ohio Courts overruled after a hearing. Beck was eventually convicted at trial, with the slips being the primary basis of that verdict. On appeal, both the Ohio Court of Appeals and the Ohio Supreme Court (the highest in the state) affirmed his conviction on the belief that the searches were part of a lawful arrest and thus valid, despite the lack of a warrant.

Question

Did the policeman's arrest and incidental search of William Beck person violate Beck's rights under the Fourth Amendment and Fourteenth Amendment, and if so, should the criminally-punishable slips be suppressed as evidence?

Holding

The majority (Stewart, joined by Warren, Douglas, Brennan, White, Goldberg) overturned the Ohio Supreme Court ruling, invalidating the arrest and all evidence obtained therefrom. They found that the policemen's justification for the arrest (especially their description of the informer) was too vague and that their suspicion relied too much on Beck's prior arrests and convictions. The Court concluded that the "record in this case does not contain a single objective fact to support a belief by the officers that the petitioner was engaged in criminal activity at the time they arrested him." [2]

The court did acknowledge that the policemen may have received information from someone, but they felt the prosecution "needed to show with considerably more specificity" what the information said, who the informer was, and why the police found the informer reliable. Otherwise, a showing of probable cause was absent. On that note, Justice Potter Stewart concluded thus: "We may assume that the officers acted in good faith. But good faith on the part of the arresting officer is not enough. If subjective good faith alone were the test, the protections of the Fourth Amendment would evaporate, and the people would be secure in their persons, houses, papers, and effects, only in the discretion of the police." [3]

The Supreme Court had three dissenters, Justice Clark, Justice Black, and Justice Harlan. Clark, with Black joining, contended that the U.S. Supreme Court should honor the probable cause determination of any State's highest court, else "this Court will be continually disputing with state and federal courts over the minutiae of facts in every search and seizure case." [4] Justice Harlan's argument was that the police had probable cause because the informer, however vague his identity and information were, said that Beck would be at "East 115th Street and Beulah," and the police did, indeed, find Beck at such place. This correspondence, Harlan felt, was enough to establish informer's reliability and, thus, enough to establish probable cause. [5] Clark, Black, and Harlan would have affirmed Beck's conviction.

Related Research Articles

<span class="mw-page-title-main">Fourth Amendment to the United States Constitution</span> 1791 amendment prohibiting unreasonable searches and seizures

The Fourth Amendment to the United States Constitution is part of the Bill of Rights. It prohibits unreasonable searches and seizures. In addition, it sets requirements for issuing warrants: warrants must be issued by a judge or magistrate, justified by probable cause, supported by oath or affirmation, and must particularly describe the place to be searched and the persons or things to be seized.

In United States criminal law, probable cause is the standard by which police authorities have reason to obtain a warrant for the arrest of a suspected criminal or the issuing of a search warrant. There is no universally accepted definition or formulation for probable cause. One traditional definition, which comes from the U.S. Supreme Court's 1964 decision Beck v. Ohio, is when "whether at [the moment of arrest] the facts and circumstances within [an officer's] knowledge and of which they had reasonably trustworthy information [are] sufficient to warrant a prudent [person] in believing that [a suspect] had committed or was committing an offense."

Mapp v. Ohio, 367 U.S. 643 (1961), was a landmark decision of the U.S. Supreme Court in which the Court ruled that the exclusionary rule, which prevents prosecutors from using evidence in court that was obtained by violating the Fourth Amendment to the U.S. Constitution, applies not only to the federal government but also to the U.S. state governments. The Supreme Court accomplished this by use of a principle known as selective incorporation; in Mapp this involved the incorporation of the provisions, as interpreted by the Court, of the Fourth Amendment which is applicable only to actions of the federal government into the Fourteenth Amendment's due process clause which is applicable to actions of the states.

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Stanley v. Georgia, 394 U.S. 557 (1969), was a U.S. Supreme Court decision that helped to establish an implied "right to privacy" in U.S. law in the form of mere possession of obscene materials.

Atwater v. Lago Vista, 532 U.S. 318 (2001), was a United States Supreme Court decision which held that a person's Fourth Amendment rights are not violated when the subject is arrested for driving without a seatbelt. The court ruled that such an arrest for a misdemeanor that is punishable only by a fine does not constitute an unreasonable seizure under the Fourth Amendment.

United States v. Leon, 468 U.S. 897 (1984), was a United States Supreme Court case in which the Court established the "good faith" exception to the Fourth Amendment exclusionary rule.

Chimel v. California, 395 U.S. 752 (1969), was a 1969 United States Supreme Court case in which the Court held that police officers arresting a person at home could not search the entire home without a search warrant, but police may search the area within immediate reach of the person without a warrant. The rule on searches incident to a lawful arrest within the home is now known as the Chimel Rule.

Ker v. California, 374 U.S. 23 (1963), was a case before the United States Supreme Court, which incorporated the Fourth Amendment's protections against illegal search and seizure. The case was decided on June 10, 1963, by a vote of 5–4.

Aguilar v. Texas, 378 U.S. 108 (1964), was a decision by the United States Supreme Court, which held that "[a]lthough an affidavit supporting a search warrant may be based on hearsay information and need not reflect the direct personal observations of the affiant, the magistrate must be informed of some of the underlying circumstances relied on by the person providing the information and some of the underlying circumstances from which the affiant concluded that the informant, whose identity was not disclosed, was credible or his information reliable." Along with Spinelli v. United States (1969), Aguilar established the Aguilar–Spinelli test, a judicial guideline for evaluating the validity of a search warrant based on information provided by a confidential informant or an anonymous tip. The test developed in this case was subsequently rejected and replaced in Illinois v. Gates, 462 U.S. 213 (1983).

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Ornelas v. United States, 517 U.S. 690 (1996), was a case decided by the Supreme Court of the United States that held that appellate courts should review probable cause determinations for warrantless searches de novo.

Stoner v. California, 376 U.S. 483 (1964), is a United States Supreme Court decision involving the Fourth Amendment. It was a criminal case appealed from the California Courts of Appeal after the California Supreme Court denied review. The case extended the situations under which search warrants are required as they reversed a robbery conviction made on the basis of evidence obtained in violation of the holding.

Kentucky v. King, 563 U.S. 452 (2011), was a decision by the US Supreme Court, which held that warrantless searches conducted in police-created exigent circumstances do not violate the Fourth Amendment as long as the police did not create the exigency by violating or threatening to violate the Fourth Amendment.

Maryland v. King, 569 U.S. 435 (2013), was a decision of the United States Supreme Court which held that a cheek swab of an arrestee's DNA is comparable to fingerprinting and therefore, a legal police booking procedure that is reasonable under the Fourth Amendment.

Elkins v. United States, 364 U.S. 206 (1960), was a US Supreme Court decision that held the "silver platter doctrine", which allowed federal prosecutors to use evidence illegally gathered by state police, to be a violation of the Fourth Amendment to the United States Constitution.

Ybarra v. Illinois was a decision of the U.S. Supreme Court which ruled that a warrant can not be used to search an unnamed individual unless the warrant mentions that unnamed parties are involved or exigent circumstances are shown to exist.

Abel v. United States, 362 U.S. 217 (1960), was a United States Supreme Court case.

Nieves v. Bartlett, 587 U.S. ___ (2019), was a civil rights case in which the Supreme Court of the United States decided that probable cause should generally defeat a retaliatory arrest claim brought under the First Amendment, unless officers under the circumstances would typically exercise their discretion not to make an arrest.

Johnson v. United States, 333 U.S. 10 (1948), was a significant United States Supreme Court decision addressing search warrants and the Fourth Amendment. In this case, where federal agents had probable cause to search a hotel room but did not obtain a warrant, the Court declared the search was "unreasonable."

References

  1. Beck v. Ohio, 379 U.S. 89, 93-94 (1964).
  2. Beck, 379 U.S. at 95.
  3. Beck, 379 U.S. at 97.
  4. Beck, 379 U.S. at 99 (Clark, J., dissenting).
  5. Beck, 379 U.S. at 101-03 (Harlan, J., dissenting).