Tuesday, November 5, 2013

Atwater v. City of Lago Vista case brief

Atwater v. City of Lago Vista case brief summary
532 U.S. 318 (2001)

Petitioners sued respondents under 42 U.S.C.S. § 1983, alleging that respondent officer violated petitioner arrestee's Fourth Amendment rights by arresting her for a seatbelt violation without a warrant. The United States Court of Appeals for the Fifth Circuit affirmed a grant of summary judgment in favor of respondents. Petitioners filed a petition for writ of certiorari to the appellate court, which was granted.

Respondent officer arrested petitioner arrestee for seatbelt violations and placed her in jail until she was released on bond. Petitioners sued respondents, alleging a Fourth Amendmentviolation. Respondents were granted summary judgment.

  • On certiorari review, the court affirmed the judgment in favor of respondents. 
  • The court determined that the Fourth Amendment does not limit police officers' authority to arrest without warrant for minor criminal offenses. 
  • Respondent officer had probable cause to believe that petitioner arrestee had committed a crime in his presence; therefore, respondent officer was authorized to make a custodial arrest without balancing costs and benefits or determining whether or not the arrest was in some sense necessary. 
  • The court rejected petitioners' argument that peace officers' authority to make warrantless arrests for misdemeanors was restricted at common law to instances of breach of the peace. 
  • The court also rejected petitioners' argument for a modern arrest rule.


Summary judgment in favor of respondents was affirmed because the Fourth Amendment did not limit respondent officer's authority to arrest petitioner arrestee without a warrant.

Recommended Supplements for Criminal Procedure Criminal Procedure: Examples & Explanations, Sixth Edition
Emanuel Law Outline: Criminal Procedure

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