532 U.S. 318 (2001)
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