Atwater v. City of Lago Vista case brief

ATWATER v. CITY OF LAGO VISTA
121 S.Ct. 1536 (2001)

Facts:  Atwater, P, was driving her pickup truck in Lago Vista, Texas, with her 3-year old son and 5-year-old daughter in the front seat. 
-Nobody was wearing a seat belt. 
-Respondent, a police officer, observed seat belt violations and pulled P over. 
-P told police officer she did not have driver’s license an insurance documentation because her purse had been stolen the day before. 
-P was arrested and booked, charged with driving without her seat belt fastened, failing to secure her children in seat belts, driving without a license, and failing to provide proof of insurance. 
-P pleaded no contest to the misdemeanor seatbelt offenses and paid $50 fine; the other charges were dismissed.

Issue: Whether the Fourth Amendment forbids a warrant-less arrest for a minor criminal offense, such as a misdemeanor seat belt violation punishable only by a fine?

Holding:  No.  Judgment affirmed.

Procedural History:  Suit initially filed against the City of Lago Vista and Chief of Police.  The City removed the suit to federal district court which ruled the Fourth Amendment claim “merit-less” and granted the City’s summary judgment motion.  The court of appeals affirmed.

Rule:  The standard of probable cause “applies to all arrests, without the need to ‘balance’ the interests and circumstances involved in particular situations.” 
-If a police officer has probable cause to believe that an individual has committed even a very minor criminal offense in his presence, he may, without violating the Fourth Amendment, arrest the offender.

P’s Argument:  Respondents had violated P’s Fourth Amendment “right to be free from unreasonable seizure,” and sought compensatory and punitive damages.  Further, that “founding-era common-law rules” forbade peace officers to make warrant-less misdemeanor arrests except in cases of “breach of the peace.”

D’s Argument: Cannot concluded that the Fourth Amendment, as originally understood, forbade peace officers to arrest without a warrant for misdemeanors not amounting to or involving breach of the peace.  There is no indication either that such a claimed rule has ever become “woeven…into the fabric” of American law.

Analysis: Neither the history of the framing era nor subsequent legal development indicates that the Fourth Amendment was originally understood, or has traditionally been read, to embrace P’s position. 
-P has cited no particular evidence that those who framed and ratified the Fourth Amendment sought to limit peace officers’ warrant-less misdemeanor arrest authority to instances of actual breach of the peace.

Dissent:  Custodial arrests are not reasonable in every circumstance.  Police officers should not have a constitutional carte blanche to arrest whenever there is probable cause to believe a fine-only misdemeanor has been committed – such would be irreconcilable with the Fourth Amendment’s command that seizures be reasonable.