![]() | This article includes a list of general references, but it lacks sufficient corresponding inline citations .(October 2024) |
Hill v. California | |
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Argued January 19 and October 21, 1970 Decided April 5, 1971 | |
Full case name | Archie William Hill, Jr. v. State of California |
Citations | 401 U.S. 797 ( more ) |
Case history | |
Prior | Certiorari to the Supreme Court of California |
Holding | |
Although the search incident to arrest was based on mistaken identity, the officers acted in good-faith based on probable cause. Chimel not applied retroactively. | |
Court membership | |
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Case opinions | |
Majority | White, joined by Burger, Brennan, Stewart, Blackmun |
Concurrence | Black |
Concur/dissent | Harlan, joined by Marshall |
Douglas took no part in the consideration or decision of the case. | |
Laws applied | |
Chimel v. California |
Hill v. California, 401 U.S. 797 (1971) was a U.S. Supreme Court decision that ruled against the retroactive application of Chimel v. California . The Court also ruled that evidence from mistaken identity arrests can be admissible as long as other factors support probable cause.
A day after four armed men robbed a Studio City residence, Los Angeles Police arrested Alfred Baum and Richard Bader for narcotics possession during a June 5, 1966 traffic stop. The stopped car was registered to Archie William Hill Jr. Both Bader and Baum confessed to taking part in the Studio City robbery after items from the crime were found in the car; they further implicated Hill. Bader told the police that he shared a Sepulveda Boulevard apartment with Hill. , Bader also stated that firearms used in the robbery and other stolen property were hidden in Hill's apartment. On June 6, Baum and Bader again implicated Hill as one of the robbers.
After Hill's association with Bader was verified, and his description was connected with statements from the Studio City victims, four officers knocked on the door of Hill's apartment; the officers possessed no search or arrest warrants. [Notes 1] Miller, a man who matched Hill's description, opened the door; the LAPD officers arrested him in the living room under the assumption that he was allegedly involved in the robbery. [Notes 2] While he confirmed that the apartment was Hill's and that he was waiting for him, Miller emphasized that there was a case of mistaken identity, and denied knowledge of any guns or stolen property.
The police testified that a semi-automatic pistol and an ammunition-feeding device were lying on a coffee table in plain view. [Notes 3] Officers then searched the apartment despite Miller producing identification. Two switchblades, a starter pistol, two improvised masks, rent receipts, property from the robbery, and two pages of Hill's diary containing a confession to the robbery were seized from the bedroom. A .22 caliber revolver was seized from under the living room sofa as well.
Hill pled innocence, and filed motions to suppress the evidence found during the search. [1] The trial court denied the motion on the basis that the officers acted in good faith. Although the prosecution's eyewitnesses were unable to identify him as one of the robbers, Hill was convicted on October 20, 1966. The California Court of Appeals reversed his conviction by arguing that the apartment search was unreasonable. [2] However, the California Supreme Court reversed the decision. [3]
In a 6-2 decision delivered by Justice Byron White, the Supreme Court declined to apply Chimel retroactively. Additionally, the Court upheld the conviction due to factors supporting probable cause for Miller's initial arrest and the subsequent search. Even though the officers made a mistake, their actions were conducted in good faith based on a combination of reasonable inferences and objective observations.
Miller attempted to challenge the diary evidence as a 5th Amendment violation under Boyd v. United States , but the Court rejected this objection as the issue was not brought up during the initial state proceedings.
While Justice John M. Harlan II agreed that there was probable cause behind the mistaken arrest of Miller and the search of the living room, he vehemently disagreed with the decision not to apply Chimel retroactively. He opined that the officers should have obtained a search warrant before searching the bedroom on the basis of Baum and Bauder revealing Hill's role a day before the search happened.
Although modern police officers have to navigate within the confines of Chimel, the decision allows officers to search a person and the immediate area on the basis of probable cause even if the arrest originated from a mistaken identity. [4] [5]
The Fourth Amendment to the United States Constitution is part of the Bill of Rights. It prohibits unreasonable searches and seizures and 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.
Terry v. Ohio, 392 U.S. 1 (1968), was a landmark U.S. Supreme Court decision in which the court ruled that it is constitutional for American police to "stop and frisk" a person they reasonably suspect to be armed and involved in a crime. Specifically, the decision held that a police officer does not violate the Fourth Amendment to the U.S. Constitution's prohibition on unreasonable searches and seizures when questioning someone even though the officer lacks probable cause to arrest the person, so long as the police officer has a reasonable suspicion that the person has committed, is committing, or is about to commit a crime. The court also ruled that the police officer may perform a quick surface search of the person's outer clothing for weapons if they have reasonable suspicion that the person stopped is "armed and presently dangerous." This reasonable suspicion must be based on "specific and articulable facts," and not merely upon an officer's hunch.
In criminal procedure law of the United States, an exigent circumstance allows law enforcement to enter a structure without a search warrant, or if they have a "knock and announce" warrant, allows them to enter without knocking and waiting for the owner's permission to enter. It must be a situation where people are in imminent danger, evidence faces imminent destruction, or a suspect's escape is imminent. Once entry is obtained, the plain view doctrine applies, allowing the seizure of any evidence or contraband discovered in the course of actions consequent upon the exigent circumstances.
United States v. Ross, 456 U.S. 798 (1982), was a search and seizure case argued before the Supreme Court of the United States. The high court was asked to decide if a legal warrantless search of an automobile allows closed containers found in the vehicle to be searched as well. The appeals court had previously ruled that opening and searching the closed portable containers without a warrant was a violation of the Fourth Amendment, even though the warrantless vehicle search was permissible due to existing precedent.
In the United States, the plain view doctrine is an exception to the Fourth Amendment's warrant requirement that allows an officer to seize evidence and contraband that are found in plain view during a lawful observation. The doctrine is also regularly used by Transportation Security Administration officers while screening people and property at American airports.
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 his home could not search the entire home without a search warrant, but that 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.
Search incident to a lawful arrest, commonly known as search incident to arrest (SITA) or the Chimel rule, is a U.S. legal principle that allows police to perform a warrantless search of an arrested person, and the area within the arrestee’s immediate control, in the interest of officer safety, the prevention of escape, and the preservation of evidence.
Arizona v. Hicks, 480 U.S. 321 (1987), held that the Fourth Amendment requires the police to have probable cause to seize items in plain view.
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.
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.
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.
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."
Chambers v. Maroney, 399 U.S. 42 (1970), was a United States Supreme Court case in which the Court applied the Carroll doctrine in a case with a significant factual difference—the search took place after the vehicle was moved to the stationhouse. The search was thus delayed and did not take place on the highway as in Carroll. After a gas station robbery, a vehicle fitting the description of the robbers' car was stopped. Inside were people wearing clothing matching the description of that worn by the robbers. They were arrested, and the car was taken to the police station where it was later searched.
United States v. Robinson, 414 U.S. 218 (1973), was a case in which the United States Supreme Court held that "in the case of a lawful custodial arrest a full search of the person is not only an exception to the warrant requirement of the Fourth Amendment, but is also a reasonable search under that Amendment."
Maryland v. Buie, 494 U.S. 325 (1990), was a decision by the Supreme Court of the United States handed down in 1990. In the case, the Court held that the Fourth Amendment permits a properly limited protective sweep in conjunction with an in-home arrest when the searching officer possesses a reasonable belief based on specific and articulable facts that the area to be swept harbors an individual posing a danger to those on the arrest scene.
Cupp v. Murphy, 412 U.S. 291 (1973), was a United States Supreme Court case in which the Court upheld a murder conviction notwithstanding a challenge that the evidence upon which guilt was based was obtained in violation of the Fourth and Fourteenth Amendments of the United States Constitution. The court held that in view of the station-house detention upon probable cause, the very limited intrusion of scraping the defendant's fingernails for blood and other material, undertaken to preserve highly evanescent evidence, did not violate the Fourth and Fourteenth Amendments.
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.
Riley v. California, 573 U.S. 373 (2014), is a landmark United States Supreme Court case in which the court ruled that the warrantless search and seizure of the digital contents of a cell phone during an arrest is unconstitutional under the Fourth Amendment.
Edwards v. Vannoy, 593 U.S. ___ (2021), was a United States Supreme Court case involving the Court's prior decision in Ramos v. Louisiana, 590 U.S. ___ (2020), which had ruled that jury verdicts in criminal trials must be unanimous under the Sixth Amendment to the U.S. Constitution. The Supreme Court ruled 6–3 that Ramos did not apply retroactively to earlier cases prior to their verdict in Ramos.
Vale v. Louisiana, 399 U.S. 30 (1970) was a search and seizure case decided by the United States Supreme Court in 1970, in which the Court held that a search of a suspect's house is not "incident to the arrest" when the suspect's arrest took place outside. The police officers therefore required a search warrant.