Henry v. the United States: Case Brief

Facts 

Henry v. the United States was argued on October 20 th and 21 st 1959, and decided on November 23th, 1959. The case relates to the theft of whiskey from a shipment at a Chicago’s terminal. The theft resulted in Pierotti and Henry arrest by FBI agents who watched them for two days and observed the two friends place cartons in Henry's motor car in a residential district twice with the same sequence, which involved leaving the tavern, get into a car, enter in the same gangway and pick up more cartoons and leave. Given the FBI agents had heard rumors that Pierotti had been implicated with interstate shipments, they assumed that the cartons were transporting the stolen whisky. However, the decision to search and seizure was based on mere rumors, but the seizure revealed that the cartons contained stolen radios.

Procedural History 

The District Court overruled Henry's petition on the illegality of the search and seizure. The Court of Appeal affirmed the decision meaning Henry remained guilty for possessing the radios worth over $100 stolen from an interstate shipment. Thus, the petitioner petitioned for a writ of certiorari, 359 U.S. 904, which overruled the previous rulings.

Issue 

The case was on whether the FBI agents had probable reason to search and seize the car, whereas Henry had no prior record of engaging in crime. Also, did the rumors that Pierotti had been involved in interstate shipment crimes warrant the search and seizure that led to discovering the stolen radios? The petitioner was adamant that he had done nothing to deserve being stopped and searched without a warrant because such searches violate the Fourth Amendment. However, do the ends justify the means given that the search and seizure resulted in arresting individuals responsible for stealing radios?

Rules 

The case was under the Fourth Amendment, which prohibits searches and seizures without warrants. Therefore, evidence from searches and seizures without warrants is inadmissible in court because they violate an individual's Fourth Amendment. However, the Fourth Amendment demands warrants, “Upon probable cause, supported by oath or affirmation, and particularly describing the place to be searched and the persons or things to be seized.” ( Henry v. United States , 1959) 

Analysis and Application 

The principle of probable cause aims to eliminate the oppressive practices by law enforcement officers in arresting and searching on suspicion or rumors and demand for probable cause and eliminate the use of general warrants that do not contain the name and the property to be seized. Also, notes that the evidence acquired cannot be used to establish guilt. However, FBI agents used the statutory authority of FBI agents and officers that allowed them to make arrests without a warrant if the felony is committed in their presence. That is, an FBI agent can arrest or search an offender he witnesses committing a felony or has reasonable grounds that the person arrested is committing a crime or committed a crime. Therefore, they believed that they were operating in 'Good Faith.'

However, good faith does not exempt probable cause whereby the transportation of cartons in a residential area does not raise any concern, and the rumors or suspicion cannot guarantee probable cause. Therefore, the overturning of prior rulings under the writ of certiorari, 359 U.S. 904, justified that the petitioner's rights were violated because the FBI agents had no reasonable cause for searching and seizing his car.

Conclusion 

The essence that the ruling resulted in the making the stolen radios inadmissible in court because the FBI agents violated Henry’s probable cause is conflicting honoring individual rights and convicting criminals. However, I believe that protecting rights is worth more than violating individual rights just to solve a crime. Therefore, the writ of certiorari, 359 U.S. 904 decision to overrule prior decision was justified because it protected individual rights.

Reference

Henry v. United States (U.S. Supreme Court 1959).