Adams v. Williams Case Brief

Why is the case important?

Robert Williams (the “Respondent”) was convicted in Connecticut state court for illegal possession of a handgun found during a “stop and frisk” and heroin found during a search incident to this weapons arrest.

Facts of the case

“During the early morning hours of October 30, 1966, an individual approached a police officer in a gas station parking lot in Bridgeport, Connecticut, and informed him that another individual in a nearby vehicle was carrying narcotics and had a gun at his waist. The officer approached the vehicle on foot and asked the occupant, Robert Williams, to open the door. When Williams rolled down the window instead, the officer reached into the car and removed a gun from Williams’ waistband, though the gun was not visible from outside the vehicle. The officer then arrested Williams for unlawful possession of a firearm and proceeded to search his vehicle, where he found heroin. Williams was convicted in a Connecticut state court of possession of a handgun and heroin.After the Supreme Court of Connecticut affirmed the conviction, Williams filed a claim against the prison warden, Frederick Adams, in which he alleged that the state of Connecticut continued to detain him unlawfully as a prisoner. Williams argued that the handgun and drugs were discovered through an unlawful search and should not have been admitted into evidence at his trial. The district court denied his petition. On appeal, the U.S. Court of Appeals for the Second Circuit sided with Williams and ordered that his conviction be set aside.”

Question

Whether a stop and frisk has to be based on the officer’s personal observation or if it can be based on information supplied by another person?

Answer

The stop and frisk can be based on information from other people. Once the arresting officer had found the gun precisely where the informant had predicted, probable cause existed to arrest Williams for unlawful possession of the weapon. Further, under the circumstances surrounding Williams’ possession of the gun seized by the officer, the arrest on the weapons charge was supported by probable cause, and the search of his person and of the car incident to that arrest was lawful.
Respondent’s argument that the officers conduct violated Terry v. Ohio was rejected. Terry found that a brief stop of a suspicious individual, in order to determine his identity or to maintain the status quo momentarily while obtaining more information, may be most reasonable in light of the facts known to the officer at the time. Additionally, so long as the officer is entitled to make a forcible stop, and has reason to believe that the suspect is armed and dangerous, he may conduct a weapons search limited in scope to this protective purpose.
The majority, in applying Terry’s above principle’s, found that the officer’s conduct in response to the informant’s tip was appropriate. The police officer knew the informant personally and had been provided information by him in the past. This is stronger than when the police receive an anonymous telephone tip. Although, while the Court’s decisions indicate that this informant’s unverified tip may have been insufficient for a narcotics arrest or search warrant, the information carried enough indicia of reliability to justify the officer’s forcible stop of Respondent.
The majority observed that the arresting officer had ample reason to fear for his own safety when he approached the Respondent in a high-crime area early in the morning. Additionally, the Respondent would not get out of his car and instead he rolled down his window making the weapon in his waist an even greater threat. Based on the facts of this case, the policeman’s action in reaching to the spot where the gun was thought to be hidden constituted a limited intrusion designed to insure his safety, and we conclude that it was reasonable.

Conclusion

“The United States Supreme Court reversed, ruling that the information carried enough indicia of reliability to justify the stop of respondent. From that, the Court ruled that the officer, having a reasonable belief that respondent was armed and dangerous, made a permissible limited protective search for the weapon at respondent’s waist, despite the fact that the weapon was not visible from the exterior of the car. Having seized the weapon, the officer was provided with probable cause to arrest respondent for its possession

  • the subsequent search incident to arrest, which produced the narcotics that formed the basis for respondent’s heroin conviction, was therefore lawful.”
    • Case Brief: 1972
    • Petitioner: Frederick E. Adams
    • Respondent: Robert Williams
    • Decided by: Burger Court

    Citation: 407 US 143 (1972)
    Argued: Apr 10, 1972
    Decided: Jun 12, 1972