Florida v. Thomas

Last updated
Florida v. Thomas
Seal of the United States Supreme Court.svg
Argued April 25, 2001
Decided June 4, 2001
Full case nameFlorida, Petitioner v. Robert A. Thomas, Respondent.
Citations532 U.S. 774 ( more )
121 S. Ct. 1905; 150 L. Ed. 2d 1
Case history
PriorEvidence suppressed during trial; suppression reversed, 711 So.2d 1241 (Fla. 2d DCA, 1998); reversed, 761 So.2d 1010 (Fla., 2000)
Holding
The writ of certiorari was improvidently granted as the Florida state courts have not made a 'reviewable final-judgement'.
Court membership
Chief Justice
William Rehnquist
Associate Justices
John P. Stevens  · Sandra Day O'Connor
Antonin Scalia  · Anthony Kennedy
David Souter  · Clarence Thomas
Ruth Bader Ginsburg  · Stephen Breyer
Case opinion
MajorityRehnquist, joined by unanimous
Laws applied
Ruling based on precedent

Florida v. Thomas, 532 U.S. 774 (2001), is a United States Supreme Court case decided in 2001. The case brought to the court concerned the extent of the Court's earlier decision in New York v. Belton , concerning whether a person was in custody, a determination central to allowing evidence seized in an automobile search to be presented in trial. However, the Court unanimously dismissed the case because the decision of the Florida state courts was not "final".

Supreme Court of the United States Highest court in the United States

The Supreme Court of the United States (SCOTUS) is the highest court in the federal judiciary of the United States. It has ultimate appellate jurisdiction over all federal and state court cases that involve a point of federal law, and original jurisdiction over a narrow range of cases, including suits between two or more states and those involving ambassadors. The Court holds the power of judicial review, the ability to invalidate a statute for violating a provision of the U.S. Constitution. It is also able to strike down presidential directives for violating either the Constitution or statutory law. However, it may act only within the context of a case in an area of law over which it has jurisdiction. The Court may decide cases having political overtones, but it has ruled that it does not have power to decide non-justiciable political questions.

New York v. Belton, 453 U.S. 454 (1981), was a United States Supreme Court case in which the Court held that when a police officer has made a lawful custodial arrest of the occupant of an automobile, the officer may, as a contemporaneous incident of that arrest, search the passenger compartment of that automobile. Therefore, Belton extended the so-called "Chimel rule" of searches incident to a lawful arrest, established in Chimel v. California (1969), to vehicles. The Supreme Court sought to establish bright line rules to govern vehicle search incident to eliminate some confusion in the cases.

Contents

Background

In Polk County, Florida, police officers went to Robert Thomas' home, investigating possible marijuana sales at his Florida home. While this was going on, Thomas drove up to his house in his car. [1] An officer asked him for his name and identification. Thomas was arrested thereafter when a search on his license showed an outstanding warrant. One officer proceeded to take him inside the house while another searched his car, finding methamphetamine. [1] He was indicted for possession. At his trial, he moved to suppress the evidence, which was subsequently granted by the trial judge. [1] In reversing, an intermediate appellate court found the search valid under New York v. Belton . In Belton, the U.S. Supreme Court established a "bright-line" rule permitting an officer who has made a lawful custodial arrest of a car's occupant to search the car's passenger compartment as an incident of the arrest. [1] In reversing the intermediate court of appeals, the Florida Supreme Court held Belton did not apply because it is limited to situations where the officer initiates contact with a vehicle's occupant while that person remains in the vehicle. The Supreme Court granted review. [1] [2] It would only be a few months before the ultimate decision, where they would dismiss the case. [3]

Polk County, Florida County in Florida, United States

Polk County is located in the U.S. state of Florida. The county population was 602,095, as of the 2010 census. Its county seat is Bartow, and its largest city is Lakeland.

Drivers license license for driver of motorized vehicles

A driver's license is an official document, often plastic and the size of a credit card, permitting a specific individual to operate one or more types of motorized vehicles, such as a motorcycle, car, truck, or bus on a public road.

A warrant is generally an order that serves as a specific type of authorization, that is, a writ issued by a competent officer, usually a judge or magistrate, which permits an otherwise illegal act that would violate individual rights and affords the person executing the writ protection from damages if the act is performed.

Opinion of the Court

In a unanimous opinion authored by Chief Justice William H. Rehnquist, the Court dismissed the writ of certiorari for want of jurisdiction. [2] [3] Rehnquist wrote that the Florida Supreme Court's decision did not fit any of the categories where the Court "treated state-court judgments as final for jurisdictional purposes although there were further proceedings to take place in the state court." [2] Thus, the Court concluded that the Florida Supreme Court's decision was not final. [3] This was partly based on a doctrine from the Cox decision which decided that certain decisions were not 'final' when the trial proceedings had not been completed. [2] [4]

In law, a majority opinion is a judicial opinion agreed to by more than half of the members of a court. A majority opinion sets forth the decision of the court and an explanation of the rationale behind the court's decision.

Cox Broadcasting Corp. v. Cohn, 420 U.S. 469 (1975), was a United States Supreme Court case involving freedom of the press publishing public information. The Court held that both a Georgia Statute prohibiting the release of a rape victim's name and its common-law privacy action counterpart were unconstitutional. The case was argued on November 11, 1974 and decided on March 3, 1975.

See also

Certiorari is a court process to seek judicial review of a decision of a lower court or administrative agency. The term comes from the name of an English prerogative writ, issued by a superior court to direct that the record of the lower court be sent to the superior court for review.

Motor vehicle exception

The motor vehicle exception is a legal rule in the United States that modifies the normal probable cause requirement of the Fourth Amendment to the United States Constitution and, when applicable, allows a police officer to search a motor vehicle without a search warrant.

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. It is also the standard by which grand juries issue criminal indictments. The principle behind the standard is to limit the power of authorities to perform random or abusive searches, and to promote lawful evidence gathering and procedural form during criminal arrest and prosecution. The standard also applies to personal or property searches.

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Traffic stop Detention of a driver by police

A traffic stop, commonly called being pulled over, is a temporary detention of a driver of a vehicle by police to investigate a possible crime or minor violation of law.

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.

Procedures of the Supreme Court of the United States U.S. Supreme Court procedures

The Supreme Court of the United States is the highest court in the federal judiciary of the United States. The procedures of the Supreme Court of the United States are governed by the U.S. Constitution, various federal statutes, and the Court's own internal rules. Since 1869, the Court has consisted of one chief justice and eight associate justices. Justices are nominated by the president, and with the advice and consent (confirmation) of the U.S. Senate, appointed to the Court by the president. Once appointed, justices have lifetime tenure unless they resign, retire, or are removed from office.

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.

Papachristou v. Jacksonville, 405 U.S. 156 (1972), was a United States Supreme Court case resulting in a Jacksonville vagrancy ordinance being declared unconstitutionally vague. The case was argued on December 8, 1971, and decided on February 24, 1972. The respondent was the city of Jacksonville, Florida.

Florida v. Rodriguez, 469 U.S. 1 (1984), was a United States Supreme Court case concerning the Fourth Amendment rights of protection from search and seizure. The case involved defendant Damasco Vincente Rodriguez against the State of Florida. After the Florida State Court and the District Court of Appeal of Florida both judged in favor of the defendant, the State of Florida appealed for a writ of Certiorari. The Supreme Court sided with the State of Florida, overturning the decision of the Florida state courts.

Maryland v. Pringle, 540 U.S. 366 (2003), is a Supreme Court of the United States case regarding the reasonableness of the arrest of a passenger in an automobile.

United States v. Brignoni-Ponce, 422 U.S. 873 (1975), was the case in which the Supreme Court determined it was a violation of the Fourth Amendment for a roving patrol car to stop a vehicle solely on the basis of the driver appearing to be of Mexican descent. A roving patrol car must have articulable facts that allow for an officer to have a reasonable suspicion that the person is carrying illegal aliens beyond their ethnicity. The Court handed down a 9-0 decision that affirmed the Circuit Court’s ruling in the case.

Arizona v. Gant, 556 U.S. 332 (2009), was a United States Supreme Court decision holding that the Fourth Amendment to the United States Constitution requires law enforcement officers to demonstrate an actual and continuing threat to their safety posed by an arrestee, or a need to preserve evidence related to the crime of arrest from tampering by the arrestee, in order to justify a warrantless vehicular search incident to arrest conducted after the vehicle's recent occupants have been arrested and secured.

Thornton v. United States, 541 U.S. 615 (2004), was a decision by the United States Supreme Court, which held that when a police officer makes a lawful custodial arrest of an automobile's occupant, the Fourth Amendment to the United States Constitution allows the officer to search the vehicle's passenger compartment as a contemporaneous incident of arrest. Thornton extended New York v. Belton, ruling that it governs even when an officer does not make contact until the person arrested has left the vehicle. Thornton also suggests a separate justification for an evidentiary search "when it is reasonable to believe evidence relevant to the crime of arrest might be found in the vehicle."

Arizona v. Johnson, 555 U.S. 323 (2009), is a United States Supreme Court case in which the Court held, by unanimous decision, that police may conduct a pat down search of a passenger in an automobile that has been lawfully stopped for a minor traffic violation, provided the police reasonably suspect the passenger is armed and dangerous.

Colorado v. Bannister, 449 U.S. 1 (1980), is a U.S. Supreme Court case concerning the automobile exception to constitutional protections against searches and seizures.

2001 term per curiam opinions of the Supreme Court of the United States

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Pennsylvania v. Mimms, 434 U.S. 106 (1977), is a United States Supreme Court criminal law decision holding that a police officer ordering a person out of a car following a traffic stop and conducting a pat-down to check for weapons did not violate the Fourth Amendment to the United States Constitution.

Bailey v. United States, 568 U.S. 186 (2013), was a United States Supreme Court case concerning search and seizure. A 6–3 decision reversed the weapons conviction of a Long Island man who had been detained when police followed his vehicle after he left his apartment just before it was to be searched. Justice Anthony Kennedy wrote the majority opinion, and Antonin Scalia filed a concurrence. Stephen Breyer dissented.

<i>Florida v. Jardines</i> United States Supreme Court case

Florida v. Jardines, 569 U.S. 1 (2013), is a decision by the United States Supreme Court which held that police use of a trained detection dog to sniff for narcotics on the front porch of a private home is a "search" within the meaning of the Fourth Amendment to the United States Constitution, and therefore, without consent, requires both probable cause and a search warrant.

<i>Florida v. Harris</i> United States Supreme Court case

Florida v. Harris, 568 U.S. 237 (2013), was a case in which the United States Supreme Court addressed the reliability of a dog sniff by a detection dog trained to identify narcotics, under the specific context of whether law enforcement's assertions that the dog is trained or certified is sufficient to establish probable cause for a search of a vehicle under the Fourth Amendment to the United States Constitution. Harris was the first Supreme Court case to challenge the dog's reliability, backed by data that asserts that on average, up to 80% of a dog's alerts are wrong. Twenty-four U.S. States, the federal government, and two U.S. territories filed briefs in support of Florida as amici curiae.

Rodriguez v. United States, 575 U.S. ___ (2015), was a United States Supreme Court case which analyzed whether police officers may extend the length of a traffic stop to conduct a search with a trained detection dog. In a 6–3 opinion, the Court held that officers may not extend the length of a traffic stop to conduct a dog sniff unrelated to the original purpose of the stop. However, the Court remanded the case to the United States Court of Appeals for the Eighth Circuit to determine whether the officer's extension of the traffic stop was independently justified by reasonable suspicion. Some analysts have suggested that the Court's decision to limit police authority was influenced by ongoing protests in Ferguson, Missouri.

Collins v. Virginia, No. 16-1027, 584 U.S. ___ (2018), was a case before the Supreme Court of the United States involving search and seizure. At issue was whether the Fourth Amendment's automobile exception permits a police officer, uninvited and without a warrant, to enter private property, approach a house, and search a vehicle parked a few feet from the house otherwise visible from off the property. In an 8–1 judgement, the Supreme Court ruled that the automobile exception does not apply to vehicles parked within the home or curtilage of a private homeowner.

References

  1. 1 2 3 4 5 532 U.S. at 776-777.
  2. 1 2 3 4 532 U.S. at 780.
  3. 1 2 3 532 U.S. at 781.
  4. 420 U.S. at 478.
<i>United States Reports</i> United States Supreme Court decisions

The United States Reports are the official record of the Supreme Court of the United States. They include rulings, orders, case tables, in alphabetical order both by the name of the petitioner and by the name of the respondent, and other proceedings. United States Reports, once printed and bound, are the final version of court opinions and cannot be changed. Opinions of the court in each case are prepended with a headnote prepared by the Reporter of Decisions, and any concurring or dissenting opinions are published sequentially. The Court's Publication Office oversees the binding and publication of the volumes of United States Reports, although the actual printing, binding, and publication are performed by private firms under contract with the United States Government Publishing Office.