Introduction
One afternoon in January 1998, Clinton Stoddard, a U. S. Border Patrol agent, was at a checkpoint on a highway north of Douglas in the state of Arizona. The area was known to be frequently used by smugglers and traffickers. Therefore, the roads were equipped with sensors alerting the officers of the presence of traffic on roads not frequently used. A car passed on a rarely used road and tripped a sensor, which alerted the agent, who decided to investigate. He found a minivan, a type of car frequently used by smugglers. An adult man was driving the minivan and retained a rigid posture.
The officer noted that the back of the van had children and a woman who peculiarly waved to him, but the driver did not wave. As the officer drove alongside the minivan, the driver abruptly tried to turn to a road to avoid the checkpoint. After making a radio inquiry about the car’s registration and finding it was registered in Douglas, he decided to stop the driver. The driver turned out to be an American man named Ralph Arvizu. After the search, the man was found to be carrying 129 pounds of marijuana. The officer immediately arrested Arvizu based on carrying a prohibited substance.
Lower Courts’ Decisions
Arvizu was arraigned in a district court for the offense of possessing marijuana with the intent to distribute the substance. In his defense, the accused argued that the officer failed to have reasonable suspicion to stop him. But the court denied the accused suppression of motion, citing the fact that the officer had reasonable suspicion because the route was frequently used by traffickers, Arvizu behaved suspiciously like a trafficker, and the minivan was the type of car used by smugglers. But the defendants appealed the ruling to the Ninth Circuit, which concluded in his favor, stating that seven out of ten were carried an innocent explanation. The court held that the factors carried little or no weight in the analysis of reasonable suspicion. Therefore, the court reversed the ruling by the district court and set Arvizu free. However, the government appealed the case to the Supreme Court.
Supreme Court Ruling
The legal issue that the Supreme Court sought to determine was whether the federal border patrol officer had reasonable grounds to believe that the accused was engaged in illegal activities along the highway. After analyzing the facts and the previous rulings, the Supreme Court held that suppression of the marijuana evidence was not necessary.
The Supreme Court Reasoning
The court argued that the totality of the events during the scene warranted the officer to conduct investigations of the accused’s car. From his observations and experience on the road, the officer was reasonable enough to make common sense inferences that the driver was trying to avoid checking instead of taking his family to their intended destination.
Facts of the Case
Raymond J. Place was intending to travel from Miami Airport to LaGuardia Airport in New York. As he was standing in line to purchase his air ticket, he aroused the suspicion of officers at the facility, prompting them to approach him on his way to the gate. The officers asked Place to show his identification and he agreed. The place also agreed to the police’s request to search his luggage, but because the flight was about to depart, they decided not to search. However, the officers realized that there were discrepancies between the tags on the man’s suitcases, which raised their suspicion. They check and realized that the provided addresses were false. Therefore, they called DEA agents at LaGuardia Airport in NY, informing them about their findings.
When he arrived in New York, the DEA officers approached Place, asked for his identification, and discovered that he did not have outstanding warrants. This time, Place declined to have his luggage checked but the officers decided to confiscate the two suitcases. The intention was to take the luggage to a judge to obtain a search warrant. The officers also gave Place the freedom to accompany them. A sniff test was conducted by a trained detection dog at Kennedy Airport about 30 minutes after the officers took the luggage. The dog positively detected the presence of narcotics in the suitcases, forcing the officers to retain the luggage from Friday till Monday. After the judge issued a search warrant on Monday that followed, a kilogram of cocaine was found in the luggage. The accused was immediately arrested and arraigned in a district court for the felony of possession of narcotics with the intent to distribute.
Lower Court’s Decision
The place was arraigned in the district court, accused of the possession of cocaine with the intent to distribute the drug. In his defense, the defendant moved to suppress the drug. He argued that the officers did not have the warrant to seize his luggage, which violated his rights under the Fourth Amendment. However, the district court denied the possession based on the reasoning that the DEA agents had a reasonable suspicion to take hold of the luggage. Although the defendant pleaded guilty to the possession of the drug, he appealed to the Second Circuit for a suppression motion. The Second Circuit reversed the decision of the district court and ruled that the seizure was prolonged and violated the principles under the previous ruling in Terry v. Ohio (1968). However, the state decided to appeal the case to the U. S Supreme Court.
Supreme Court Decision
At the Supreme Court, the legal question was whether the 90-minute seizure of the luggage amounted to a valid investigative stop under the Terry v. Ohio (1968) court ruling. In addition, the court sought to determine whether the sniff test by a dog was a valid search. A majority decision was reached in which the judges ruled that both questions were negative.
Supreme Court Reasoning
The 90-minute seizure of the luggage was found to be an invalid investigative stop under the Terry v. Ohio (1968) court ruling and the sniff test by a dog was an invalid search. The court held that seizures according to investigation detentions can only be lawful only when they have a limited scope as described in the preceding case law. Evidence resulting from an unlawful seizure should be suppressed, which meant that the ruling by the appeal court was held. In addition, the SC reasoned that within the Fourth Amendment, a sniff test by a properly trained detection dog cannot be considered a valid search. Consequently, the court found that the seizure of Place’s luggage for a prolonged period and the use of an unlawful search method violated his rights under the Fourth Amendment (Berger, 2020). As per the Fourth Amendment, seizures of personal belongings should not take place without a valid warrant supported by probable cause and a description of the objects to be held.
Conclusion
These two court cases demonstrate that the legality of the scope of a police search and seizure during an investigatory stop and frisk is a controversial legal question. There are two sources of law for this particular legal question- the Fourth Amendment and the ruling in the case law Terry versus Ohio (1968). The Fourth Amendment protects citizens from warrantless and unnecessary searches by law officers. On its part, the ruling in Terry versus Ohio (1968) seeks to include an additional aspect known as reasonable suspicion. This concept ensures that stopping and searching or frisking a person by law enforcers should only be considered when there is enough reason to suspect that a person is carrying illegal possessions (Berger, 2020). The reasonable suspicion does not consider but overrules the concept of “probable cause to believe” in determining whether stopping and searching a citizen is necessary and lawful.
Reference
Berger, T. A. (2020). Investigative criminal procedure in focus. Wolters Kluwer Law & Business Publishers.