Sunday, November 3, 2013

United States v. Watson case brief

United States v. Watson case brief summary
423 U.S. 411 (1976)

The government sought review of a judgment from the United States Court of Appeals for the Ninth Circuit, which reversed defendant's conviction for possession of stolen mail in violation of 18 U.S.C.S. § 1708.

Defendant's conviction for possession of stolen mail, 18 U.S.C.S. § 1708, was reversed when the appellate court determined that the warrantless arrest of defendant violated his Fourth Amendment rights and that the post-arrest search of defendant's car was coerced.

  • On certiorari, the United States Supreme Court reversed. 
  • The Court first ruled that defendant's arrest did not violate the Fourth Amendment because 
  • (1) it was based upon probable cause, as the government acted upon information from a reliable informant that defendant possessed stolen cards; and 
  • (2) the arrest was made pursuant to 18 U.S.C.S. § 3061(a)(3) and 39 C.F.R. § 232.5(a)(3), which authorized the government to make warrantless felony arrests upon reasonable grounds. 
  • Therefore, the Court ruled the post-arrest search of defendant's car to which defendant consented to, and which yielded the credit cards upon which his conviction was based, had not been the product of an illegal arrest. 
  • That defendant was not informed of his right to refuse consent to the search did not render the search invalid.


The Court reversed the judgment of the court of appeals.

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

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