United States v. Watson

Facts of the Case

A postal inspector received from an informant of known reliability a stolen credit card that respondent had given the informant to be used for their mutual advantage, and the inspector was told by the informant that respondent had agreed to furnish additional cards. At the inspector’s suggestion, a meeting was arranged between the informant and respondent for a few days later, which took place at a restaurant. Upon a prearranged signal from the informant that respondent had the additional cards, postal officers made a warrantless arrest of respondent, removed him from the restaurant, and gave him Miranda warnings. When a search of respondent’s person revealed no cards, a consented search of his nearby car (after respondent had been cautioned that the results could be used against him) revealed two additional cards in the names of other persons. Following an unsuccessful motion to suppress, these cards were used as evidence in respondent’s trial, which resulted in his conviction of possessing stolen mail. On appeal, the Court of Appeals reversed, ruling that the

Question

Did the arrest and following search of the respondent’s car violate his Fourth Amendment rights?

CONCLUSION

No. Justice Byron R. White delivered the opinion of the 6-2 majority. The Court held that postal inspectors have the power to execute an arrest without a warrant when there is probable cause. Congress has granted this power to several federal agencies, not just the postal service. Because Watson’s arrest was constitutional, the search of his car was not the product of an illegal arrest. The Court held that there was no evidence that Watson was coerced into agreeing to the car search.In his concurring opinion, Justice Lewis F. Powell wrote that there was established historical precedent for warrantless arrests. He also argued that interpreting the Fourth Amendment as always requiring a warrant prior to arrest would severely and negatively impact effective law enforcement. Justice Potter Stewart wrote a concurring opinion where he argued that the arrest occurred with probable cause, in broad daylight, in a public place and thus did not violate the Fourth Amendment. He also held that the majority’s decision in this case does not set any precedent regarding under what circumstances an officer may make a warrantless arrest in a private place.Justice Thurgood Marshall wrote a dissent and argued that the majority’s opinion grants police broad powers to make warrantless arrests and breaks with precedents already set regarding the Warrant Clause of the Fourth Amendment. He argued that the majority’s opinion goes beyond the bounds of the case in question and misinterprets common law history. He wrote that the Fourth Amendment was intended to protect people, not places, and that the interests of the people would be best served with a warrant requirement. The warrant requirement would not unduly burden the police because there is no reason to assume that it would cause any delay in an arrest, unless exigent circumstances are present, in which case the arrest may be made without a warrant. He also argued that the government did not meet its burden to show that Watson’s consent was not coerced. Justice William J. Brennan, Jr. joined in the dissent.Justice John Paul Stevens took no part in the discussion or decision in this case.

Case Information

  • Citation: 423 US 411 (1976)
  • Argued: Oct 8, 1975
  • Decided Jan 26, 1976Granted: Feb 18, 1975