The United States' criminal justice system is found on the pillar that suspects are innocent until proven guilty. The justice system relies on evidence to prove whether a suspect is innocent or guilty. The United States has federal rules regarding the evidence used in courts and state rules of evidence. The federal laws regarding evidence were enacted by congress in 1975 with the aim of ensuring fair proceedings, guide court determinations, and promote the advancement of evidence law (LawShelf). The evidence provided in courts can either be testimonies, including oral statements and affidavits, exhibits, or demonstrative evidence such as fingerprints. Fingerprints have been used in the United States' courts as primary evidence in many court cases. This research will focus on Davis v. Mississippi, 394 U.S. 721 (1969) case to examine fingerprints' validity as the primary evidence in a court case. Further, this research will review the collection and use of fingerprints as evidence in relation to the U.S. constitution's fourth amendment. Finally, this paper will include thorough research on justifications supporting the use of fingerprints as authentic evidence in U.S. courts.
The police were investigating a rape case in Meridian, Mississippi, using a general physical description of the suspect. The police had a set of fingerprints that had been taken from the scene. Davis, along with other African American youths, were arrested with a warrant since they matched the description given at the crime scene. The youths were held in a police station for questioning and fingerprinting, after which they were all released. After some time, the police arrested Davis without a warrant of arrest and drove him to Jackson, where he was locked for the night ("Davis v. Mississippi, 394 U.S. 721 (1969)", 2020). Davis was then questioned and fingerprinted a second time, after which the prints were taken to the Federal Bureau of Investigation (FBI) for assessment with the prints found on the scene of the crime. Davis's fingerprints were found to match the suspect's prints, and the fingerprint evidence was added to his trial for rape. At the trial, Davis objected to the use of the fingerprint evidence on the grounds of unlawful seizure, which were a violation of his rights according to the 4th amendment ("Davis v. Mississippi, 394 U.S. 721 (1969)", 2020). Davis also argued that he was detained illegally since the police did not have an arrest warrant and did not adhere to the 48 hours rule where a suspect should not be detained for periods longer than 48 hours without being taken to court. However, the Mississippi state court disagreed with Davis' concerns and admitted the fingerprint evidence into his case, after which he was convicted. Davis later appealed his case in the Mississippi Supreme Court, but his conviction by the State Court was upheld.
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The Fourth Amendment
Fagan (1980), in the Fourth Amendment in-Court Identification Journal, notes that the fourth amendment provides security for persons, property, papers, and effects against unwarranted seizure and police searches. The United States justice system developed the principles of the exclusionary rule, which deters the prosecution from using evidence that was obtained illegally. The exclusionary rule strengthens the fourth amendment by discouraging unconstitutional police behavior where illegal evidence is used as evidence, thus weakening the suspects' guarantees in the constitution. Further, the exclusionary rule maintains judicial integrity since by admitting illegal evidence, the courts would be justifying the means used to obtain the evidence. The sanity of the judicial processes is based on the courts' ability to follow the constitution when admitting evidence strictly.
Davis' argument that the fingerprint should not have been used since it was illegal was valid per the fourth amendment. As quoted in ("Davis v. Mississippi, 394 U.S. 721 (1969)", 2020), fingerprint evidence that is obtained through illegal seizure and search is inadmissible in a court of law. Also, the fourth amendment would have found the evidence to go against the five rules of evidence since it involved involuntary detention during the investigatory stages of the rape case. According to the five rules of evidence, information against a suspect should be admissible, accurate, complete, dependable, and plausible (LawShelf). However, when applying the fourth amendment in court cases, the court risks losing key evidence that can be used to prove the case. The exclusionary rule failed to apply in Davis v. Mississippi case since the court had to balance judicial integrity and criminal prosecution success. The Mississippi court admitted the fingerprint evidence regardless of being deterred by the 4th amendment and the exclusionary law since the fingerprint evidence against Davis would have been found anyway from the first fingerprints. The state court argued against David's objection to using the fingerprint evidence on the basis that the evidence was trustworthy (FindLaw, 2020) . However, the exclusionary rule was enacted to regulate the government agencies from overreaching suspects to prove a case.
Illegal detention of Davis for more than 48 hours to facilitate questioning and fingerprinting was in violation of the fourth amendment. According to Mulroy (2013), it is unconstitutional for police to detain suspects for more than 48 hours without the intent of presenting them before a court of law. Mulroy (2013) argues that deliberate detention violates the suspects' standard procedural protections and derails the suspects' bail determination. Furthermore, detaining a suspect for more than 48 hours violates the sixth amendment right, which protects the suspects from unlawful interrogation (Amar, 1996). The sixth amendment advocates for a fair trial for all suspects regardless of the nature of the committed offense. Also, the sixth amendment grants suspect the right to a speedy trial to minimize the detention period. However, Mulroy (2013) notes that most police detain suspects for long to achieve confession, making the case easier to prove before a court. Most suspects are detained for more than 48 hours without judicial scrutiny for police to continue investigating. The illegal detention happens without a determination by a court of law that the suspect can interfere with the witnesses or evidence when set free after the arrest. In Davis' case, the police detained him to collect more fingerprints regardless of Davis and the other youths being fingerprinted on the day of arrest. Therefore, the Mississippi court went against the fourth and sixth amendments to admitting evidence obtained under Davis's illegal detainment, the defendant.
The constitutional requirement of probable cause requires police to take suspects from their places of residence to another place only if there is an apparent cause. The probable cause requirement applies to cases where suspects are taken from their residence to police headquarters, either for custodial interrogation or fingerprinting (Mulroy, 2013). The fourth amendment forbids the transport and detainment of a suspect for anything less a definite cause. However, the law has an exception that a suspect can be briefly detained and relocated if found in a public place and shows reasonable suspicion. In this case, the police have to prove that the detained suspects match the victims' descriptions beyond a reasonable doubt. In the case of Davis v. Mississippi, the state argued that detaining the suspect was a particular case that did not necessitate a probable cause. First, the state argued that the relocation and detainment happened during the investigation stage and not the accusation stage. Therefore, the seizure was exempt from probable cause (FindLaw, 2020) . Besides, the state argued that detaining the suspect for the primary objective of acquiring available evidence did not require a probable cause. However, the fourth amendment covers a suspect during all stages of obtaining evidence, and therefore, the state violated the fundamental rights of privacy.
In summary, the Davis v. Mississippi case involved a rape allegation that used fingerprint evidence as the primary evidence in court. Davis was arrested and fingerprinted before being released together with a group of youths that matched the victim's description. Later Davis was rearrested, detained, and fingerprinted. The second fingerprints matched the prints found at the scene, and David was convicted, a ruling that was later supported by the Supreme Court. Davis argued that the seizure and detainment were against his right in the fourth amendment. According to the fourth amendment, any evidence collected in an unconstitutional method cannot be used in court. As such, this research has identified that the police violated Davis' privacy by arresting and detaining him without a warrant. Also, this research found the state of violating the sixth amendment and the probable cause requirement by approving the defendant's relocation and detainment for more than 48 hours for the sole reason of obtaining evidence. This research finds no merit that the fingerprint evidence was admissible in court based on its trustworthiness. The trustworthiness of the evidence does not make it subject to the Fourth Amendment's vetoes. Finally, regardless of the evidence proving the rape case, the use of fingerprint evidence that was collected unconstitutionally jeopardizes the rule of law and the integrity of The United States Justice System.
References
Amar, A. (1996). Foreword: Sixth Amendment First Principles . https://digitalcommons.law.yale.edu/fss_papers/937/
Davis v. Mississippi, 394 U.S. 721 (1969) . (2020). https://supreme.justia.com/cases/federal/us/394/721/
Fagan, T. (1980). Fourth Amendment-in-Court Identifications . https://scholarlycommons.law.northwestern.edu/jclc/vol71/iss4/7/
Findlaw. (2020). Findlaw's United States Supreme Court Case and Opinions. https://caselaw.findlaw.com/us-supreme-court/394/721.html
GPO. (n.d). Fourth Amendment : Search and Seizure . http://www.gpo.gov/fdsys/pkg/GPO-CONAN-1992/pdf/GPO-CONAN-1992-10-5.pdf
Mulroy, S. (2013). "Hold" On: The Remarkably Resilient, Constitutionally Dubious 48-Hour Hold. https://scholarlycommons.law.case.edu/caselrev/vol63/iss3/6/
