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Keywords

damagesstatutecompliancedue processgood faithseizure
damagesstatuteinjunctiondue processpunitive damagesappelleedeclaratory judgment

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Kolender v. Lawson, 461 U.S. 352, 103 S.Ct. 1855, 75 L.Ed.2d 903

Facts

Edward Lawson was arrested and convicted multiple times under California Penal Code § 647(e), which mandated that individuals loitering or wandering provide identification when requested by police. Lawson brought a civil action in federal court, arguing that the statute was unconstitutional for being overbroad and vague. The District Court ruled in his favor, finding the statute unconstitutional and enjoining its enforcement, while also denying Lawson damages against the officers involved due to their good faith belief in the lawfulness of their actions.

Appellee Edward Lawson was detained or arrested on approximately 15 occasions between March 1975 and January 1977 pursuant to Cal.Penal Code § 647(e). Lawson was prosecuted only twice, and was convicted once. The second charge was dismissed.

Issue

Is California Penal Code § 647(e) unconstitutionally vague, thereby violating the Due Process Clause of the Fourteenth Amendment?

The statute, as drafted and as construed by the state court, is unconstitutionally vague on its face within the meaning of the Due Process Clause of the Fourteenth Amendment by failing to clarify what is contemplated by the requirement that a suspect provide a 'credible and reliable' identification.

Rule

A penal statute must define criminal offenses with sufficient definiteness that ordinary people can understand what conduct is prohibited and must not encourage arbitrary enforcement.

As generally stated, the void-for-vagueness doctrine requires that a penal statute define the criminal offense with sufficient definiteness that ordinary people can understand what conduct is prohibited and in a manner that does not encourage arbitrary and discriminatory enforcement.

Analysis

The Supreme Court found that § 647(e) failed to provide clear standards for what constituted 'credible and reliable' identification, thus granting police officers virtually unfettered discretion in determining compliance. This vagueness allowed for arbitrary enforcement, as individuals could be punished for failing to provide identification without clear guidelines on what was required. The Court emphasized that the statute's lack of clarity undermined the constitutional protections against unreasonable searches and seizures.

The statute, as presently drafted and construed by the state courts, contains no standard for determining what a suspect has to do in order to satisfy the requirement to provide a 'credible and reliable' identification. As such, the statute vests virtually complete discretion in the hands of the police to determine whether the suspect has satisfied the statute and must be permitted to go on his way in the absence of probable cause to arrest.

Conclusion

The Supreme Court affirmed the lower court's ruling that California Penal Code § 647(e) was unconstitutionally vague and enjoined its enforcement.

We conclude § 647(e) is unconstitutionally vague on its face because it encourages arbitrary enforcement by failing to describe with sufficient particularity what a suspect must do in order to satisfy the statute.

Who won?

Edward Lawson prevailed in the case as the Supreme Court ruled that the statute was unconstitutionally vague, which protected individuals from arbitrary enforcement by law enforcement.

Lawson then brought a civil action in the District Court for the Southern District of California seeking a declaratory judgment that § 647(e) is unconstitutional, a mandatory injunction seeking to restrain enforcement of the statute, and compensatory and punitive damages against the various officers who detained him.

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