Case Brief One
Parties:
California (Plaintiff) v. Hodari D., 499 U.S. 621, 111 S.Ct. 1547 (1991) (Defendant)
Facts:
In April of 1988, two police officers dressed in civilian clothes but wearing jackets embossed with "Police" on the back and front. The two officers were on patrol in an unmarked car in a high-crime area. They noticed a group of youth was clustered around a car parked at a curb within sight of the officer's car. Officer Pertoso decided to pursue the youth group on foot while his partner drove around with the car. The group panicked and fled, including the accused. Pertoso went around the block to intercept the accused, who fled into an alley. Hodari, a juvenile, was running and looked behind him and did not see Pertoso until the officer was almost upon him, where he tossed away what appeared to be a small rock. The officer tackled him and handcuffed him recovered the small rock, which was later discovered as crack cocaine. Hodari also had $130 in his possession.
Prior Proceedings:
In the California state court's juvenile proceedings, Hodari asked the court to suppress crack cocaine evidence. He claimed that the pursuit had captured him, and the seizure of the cocaine was unreasonable. The court denied the motion and was convicted on the charges. Later, Hodari appealed to the California Court of Appeal and argued that (a) he only run because he saw the officer run toward him. (b) that the seizure was unreasonable under the Federal Constitution's Fourth Amendment. (c) the crack cocaine evidence has to be suppressed since it was from an illegal seizure. The court reversed the sentencing since the officer did not have sufficient reason to pursue Hodari and the evidence was a fruit of an unlawful seizure.
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Issues Presented or Questions of Law:
The question of law in this situation revolves around the intent of the arrest. Was Hodari arrested for being in the parking lot late at night, or was he arrested for crack cocaine possession? The court decided to dismiss the crack cocaine charges because the evidence was from an illegal seizure. The arrest should have been for being at the wrong place at the wrong time. Therefore, the California Court of Appeal decided to dismiss the crack cocaine charges.
Arguments or Objectives of the Parties:
In the case of Hodari's arrest, he brought forth an argument not to be charged based on crack cocaine possession. His defense was that the arrest was not based on crack cocaine possession but rather on failing to comply with halting to the officer's "show of authority" and being at the wrong place at the wrong time. Thus, the crack cocaine was abandoned while running and was not a fruit of the seizure. When he appealed to the California Court of Appeal, the case was overturned since officer Pertoso gathered the evidence through an illegal seizure.
Holding or Rule of Law
The seizure did not occur at the time the accused dropped the drugs.
Rationale
The court explored the scenario of what would constitute a legal seizure. The arrest would have been legal if the application of force with lawful authority was sufficient to subdue the defendant during the time of the arrest. But in this case, there was no prior contact between the two to Hodari disposing of the cocaine. The purpose of the Fourth Amendment is to prevent "arbitrary and oppressive interference by enforcement officials with the privacy and personal security of individuals" (What Does the Fourth Amendment Mean?, 2021). However, it is only applicable to cases that are deemed unreasonable under the law. The court also found that the test of a show of authority was objective, and Hodari was not seized until he was tackled. Therefore, the cocaine was disposed of while the defendant was fleeing, making it an unfruitful seizure and not excludable.
References
What Does the Fourth Amendment Mean? (2021). United States Courts. https://www.uscourts.gov/about-federal-courts/educational-resources/about-educational-outreach/activity-resources/what-does-0#:~:text=The%20Constitution%2C%20through%20the%20Fourth,deemed%20unreasonable%20under%20the%20law.
