U.S. Supreme Court 05-31-11
by: Grapkoch • May 30, 2011 • no comments
Read the full article for details about the following new cases:
- Subjective Motivations and the Fourth Amendment
The Court handed down an opinion today in Ashcroft v. Al-Kidd, which asked whether the Fourth Amendment prohibits an officer from executing a valid material witness warrant (18 U.S.C. § 3144) with the subjective intent of conducting further investigation or preventively detaining the subject. Al-Kidd had argued that the Fourth Amendment was violated because the AG used material witness warrants as a pretext to detain suspects for whom he did not have probable cause to arrest. However, the Court holds that "an objectively reasonable arrest and detention of a material witness pursuant to a validly obtained warrant cannot be challenged as unconstitutional on the basis of allegations that the arresting authority had an improper motive."
In reaching this conclusion, the Court explains that this case does not fall into any of the exceptions to the general rule that subjective motivations are irrelevant primarily because the judicial warrant at issue was based on "individualized suspicion." After first clarifying that "suspicion" is not limited to a belief "that the person suspected has engaged in wrongdoing"-but rather connotes a belief as to any connection with a crime- the Court explains that this case does not fall within the contours of Indianapolis v. Edmond, 531 U.S. 32 (2000) (prohibiting suspicionless, programmatic searches based solely a general interest in crime control). That is so because it was not the absence of probable cause that triggered Edmonds invalidating-purpose inquiry, but the checkpoints' failure to be based on "individualized suspicion."
Furthermore, neither the "special needs" nor the "administrative inspection" exceptions to the Fourth Amendment subjective motivation-rule apply to this case "[b]ecause those exceptions do not apply where the officer's purpose is not to attend to the special needs or to the investigation for which the administrative inspection is justified .The Government seeks to justify the present arrest on the basis of a properly issued judicial warrant-so that the special-needs and administrative-inspection cases cannot be the basis for a purpose inquiry here."
In sum, the Court appears to fashion a rule stating that a subjective motivation inquiry under the Fourth Amendment is foreclosed where the case involves a judicial warrant issued upon any individualized suspicion relating to law enforcement. Here, the judicial warrant established a qualifying suspicion that Al-Kidd was a material witness within the meaning of 18 U.S.C. § 3144 and hence subject to detention. Therefore, the subjective motivations of the applying officer were irrelevant.
More information on Ashcroft v. Al-Kidd can be found at the SCOTUSblog case page, available here.
