Devenpeck v. Alford Case Brief

Facts of the Case

“Petitioner police officers pulled respondent over on suspicion of impersonating a police officer, and arrested him for violating the state’s privacy act after they discovered he was taping their conversation. Respondent filed suit, challenging the constitutionality of his arrest. A jury found for the officers. The U.S. Court of Appeals for the Ninth Circuit reversed, concluding the officers did not have probable cause to arrest. Although respondent’s taping of petitioners was not a crime, the appellate court rejected petitioners’ claim that there was probable cause to arrest for obstructing or impersonating a law enforcement officer, because those offenses were not “closely related” to the offense invoked by the officer at the time of arrest. Certiorari was granted and the Supreme Court reversed and remanded.”

Question

Does a fact (other than a prior conviction) necessary to increase a sentence beyond the statutory standard range need to be proved by a jury and beyond a reasonable doubt?

CONCLUSION

No. In a unanimous opinion delivered by Justice Antonin Scalia, the Court held that police had probable cause to arrest Alford for impersonating a police officer, despite the fact that this was not closely related to the offense police identified during the arrest. A warrantless arrest by a police officer is reasonable under the Fourth Amendment if, given the facts known to the officer, there is probable cause to believe a crime has been or is being committed. The offense establishing probable cause need not be closely related to the offense the arresting officer identifies at the time of arrest. An arresting officer’s state of mind, except for facts he knows, is irrelevant to probable cause.

Case Information

Citation: 543 US 146 (2004)
Granted: Apr 19, 2004
Argued: Nov 8, 2004
Decided: Dec 13, 2004
Case Brief: 2004