Hayes v. Florida Case Brief

Why is the case important?

The police brought a suspect to the station and took his fingerprints without having probable cause until after his fingerprints were taken.

Facts of the case

Question

Whether the Fourth Amendment to the Constitution of the United States, applicable to the States by virtue of the Fourteenth Amendment, was properly applied by the District Court of Appeal of Florida, Second District, to allow police to transport a suspect to the station house for fingerprinting, without his consent and without probable cause or prior judicial authorization.

Answer

No, the judgment has to be reversed. Here, as in Davis v. Mississippi, there was no probable cause to arrest, no consent to the journey to the police station, and no judicial authorization for such a detention for fingerprinting purposes. None of our later cases have undercut the holding in Davis that transportation to and investigative detention at the station house without probable cause or judicial authorization together violate the Fourth Amendment.
There is no doubt that at some point in the investigative process, police procedures can qualitatively and quantitatively be so intrusive with respect to a suspect’s freedom of movement and privacy interests as to trigger the full protection of the Fourth and Fourteenth Amendments. And our view continues to be that the line is crossed when the police, without probable cause or a warrant, forcibly remove a person from his home or other place in which he is entitled to be and transport him to the police station, where he is detained, although briefly, for investigative purposes. We adhere to the view that such seizures, at least where not under judicial supervision, are sufficiently like arrests to invoke the traditional rule that arrests may constitutionally be made only on probable cause.
Neither reasonable suspicion nor probable cause would suffice to permit the officers to make a warrantless entry into a person’s house for the purpose of obtaining fingerprint identification.

Conclusion

The Court held that police officers acting without probable cause and without a warrant violated the Fourth Amendment, made applicable to the states by the Fourteenth Amendment, by forcibly removing a person from his home or other place where he was entitled to be and transporting him to the police station for fingerprinting. According to the Court, fingerprints taken under these circumstances were the inadmissible fruits of an illegal detention. As such, the Court reversed the judgment of the district court, averring that defendant had been detained involuntarily, and the fingerprint was obtained as the result of such involuntary detention.

  • Case Brief: 1985
  • Petitioner: Hayes
  • Respondent: Florida
  • Decided by: Burger Court

Citation: 470 US 811 (1985)
Argued: Jan 9, 1985
Decided: Mar 20, 1985