Why is the case important?
On ruling regarding a suppression hearing, the Seventh Circuit Court of Appeals (Seventh Circuit) held that the findings of a trial judge regarding probable cause and reasonable suspicion were to be given great deference, and reversed only for clear error.
Facts of the case
Saul Ornelas and Ismael Ornelas-Ledesma were arrested in Wisconsin after suspicious activity led to the discovery of cocaine in the defendants’ car. In a motion to suppress the evidence, the defendants alleged that their Fourth and Fourteenth Amendment rights were violated in their detainment and in the police search of the car. The District Court denied the motion and the defendants pleaded guilty. The Court of Appeals ultimately affirmed the District Court but for different reasons.
Are a trial court’s determinations of reasonable suspicion and probable cause subject to de novo review?
Yes. The Appellate Court should have reviewed the Trial court’s reasonable suspicion and probable cause determinations de novo.
“The Supreme Court of the United States vacated the judgment and remanded the matter to the intermediate appellate court to review de novo the district court’s determinations that the officer had reasonable suspicion and probable cause. As a general matter, the Court ruled, for purposes of the Fourth Amendment , whether law enforcement officers had reasonable suspicion to stop persons and probable cause to make a warrantless search should be reviewed de novo, rather than “”deferentially”” and “”for clear error.”””
- Case Brief: 1996
- Petitioner: Ornelas
- Respondent: United States
- Decided by: Rehnquist Court
Citation: 517 US 690 (1996)
Argued: Mar 26, 1996
Decided: May 28, 1996