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Devenpeck v. Alford, 543 U.S. 146, 125 S.Ct. 588, 160 L.Ed.2d 537, 73 USLW 4038, 04 Cal. Daily Op. Serv. 10,878, 2004 Daily Journal D.A.R. 14,750, 18 Fla. L. Weekly Fed. S 42

Facts

On November 22, 1997, Officer Joi Haner of the Washington State Patrol stopped Jerome Alford, suspecting him of impersonating a police officer after receiving reports from stranded motorists. During the stop, Alford was found to be recording the officers' conversation, leading to his arrest for violating the Washington Privacy Act. The state trial court later dismissed the charges, prompting Alford to file a federal lawsuit claiming his arrest violated his constitutional rights.

On the night of November 22, 1997, a disabled automobile and its passengers were stranded on the shoulder of State Route 16, a divided highway, in Pierce County, Washington.

Issue

Whether an arrest is lawful under the Fourth Amendment when the criminal offense for which there is probable cause to arrest is not 'closely related' to the offense stated by the arresting officer at the time of arrest.

Whether an arrest is lawful under the Fourth Amendment when the criminal offense for which there is probable cause to arrest is not 'closely related' to the offense stated by the arresting officer at the time of arrest.

Rule

A warrantless arrest by a law officer is reasonable under the Fourth Amendment if, given the facts known to the officer, there is probable cause to believe that a crime has been or is being committed.

A warrantless arrest by a law officer is reasonable under the Fourth Amendment if, given the facts known to the officer, there is probable cause to believe that a crime has been or is being committed.

Analysis

The Supreme Court found that the Ninth Circuit's requirement that the offense establishing probable cause must be 'closely related' to the offense stated by the arresting officer was inconsistent with precedent. The Court emphasized that the subjective intent of the officer is irrelevant to the existence of probable cause, and that the facts known to the officer at the time of the arrest are what determine the legality of the arrest.

The rule that the offense establishing probable cause must be 'closely related' to, and based on the same conduct as, the offense identified by the arresting officer at the time of arrest is inconsistent with this precedent.

Conclusion

The Supreme Court reversed the Ninth Circuit's decision and remanded the case for further proceedings, stating that the question of whether the officers had probable cause to arrest Alford for impersonating an officer or obstructing justice was not decided by the lower court.

Accordingly, we reverse the judgment of the Ninth Circuit and remand the case for further proceedings consistent with this opinion.

Who won?

The Supreme Court ruled in favor of the officers, stating that the Ninth Circuit's limitation on probable cause was not supported by precedent.

The Supreme Court ruled in favor of the officers, stating that the Ninth Circuit's additional limitation—that the offense establishing probable cause must be 'closely related' to, and based on the same conduct as, the offense the arresting officer identifies at the time of arrest—is inconsistent with this Court's precedent.

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