Introduction to 4th search and seizure Arkansas

SEARCH
AND
SEIZURE
Introduction to the 4th
Amendment to the US
Constitution

THE FOURTH AMENDMENT
“The right of the people to be
secure in their persons,
houses, papers, and effects,
against unreasonable
searches and seizures, shall
not be violated, and no
Warrants shall issue, but upon
probable cause, supported by
Oath or affirmation, and
particularly describing the
place to be searched, and the
persons or things to be
seized.”

THREE KEY WORDS
4th AMENDMENT
The Founding Fathers did not convey a definition of these
three words though—the Courts have been forced to
define them and give us guidance.
UNREASONABLE SEARCH SEIZURE

WHICH COURT GIVES US GUIDANCE?
Court Structure
CIRCUIT
COURT
ARKANSAS
COURT OF
APPEALS
ARKANSAS
SUPREME
COURT
Arkansas
Iowa
Minnesota
Missouri
Nebraska
North Dakota
South Dakota
8TH
CIRCUIT
COURT OF
APPEALS
UNITED
STATES
SUPREME
COURT

SEARCH AND
SEIZURE DEFINED
Actions that evoke a 4th Amendment claim must involve the “Government”.
Private party actions do not apply to 4th Amendment.
Government interference
with freedom of movement
(by means of physical
force or show of authority).
Reasonable belief not free
to terminate the encounter
at will.
SEIZURE
Government intrusion upon
a reasonable expectation
of privacy.
SEARCH

 A seizure occurs when a person submits to the commands of an
officer OR
 One acting under the color of law OR
 Is restrained by physical force, however slight, which facilitated
submission.
HORTON v. CALIFORNIA
496 U.S. 128 (1990)

“What a person knowingly exposes to the public,
even in his home, is not a subject of Fourth
Amendment protection. But what he seeks to
preserve as private, even in an area accessible to
the public may be constitutionally protected.”
KATZ V. UNITED STATES
389 U.S. 347 (1967)

“The fourth amendment protects reasonable expectations of
privacy rather than simply places. If the inspection by police
does not intrude upon a reasonable expectation of privacy,
there is no search subject to the warrant clause.”
REASONABLE EXPECTATION
OF PRIVACY

EXCLUSIONARY
RULE
If evidence is seized or discovered in a
way that violates the Fourth
Amendment (that is to say in a way that
is unreasonable and/or without
probable cause) then the exclusionary
rule provides that such evidence may
be suppressed and cannot be used
against the accused.

“The exclusionary
prohibition extends
as well to the indirect
as the direct
products of such
invasions” (Wong
Sun v. Unites States
{1963})
ALL EVIDENCE
FROM SAME
ORIGIN
“Under the fruit of the
poisonous tree doctrine, all
evidence derived from the
exploitation of an illegal
search or seizure must be
suppressed”
SUPPRESSED AND
UNABLE TO BE USED
AGAINST DEFENDANT
FRUIT OF THE
POISONOUS TREE
Remedy for searches that are deemed to
violate 4th Amendment protections.

WARRANT
REQUIREMENT
The amendment does not mandate a
warrant for all searches and seizures, the
underlying premise is that if the officer has
time a warrant should be secured.
The general rule, of course, is that a search
or seizure without a warrant is presumed to
be unreasonable and therefore unlawful.

WARRANT
REQUIREMENT
Warrants issued by a judge are presumed
reasonable. The burden of proof falls on the
defense to prove a search warrant signed by a
judge was unreasonable.
The warrant must be issued by a
disinterested magistrate.
The magistrate must find probable
cause to believe that the place to
be searched contains items
connected with criminal activity.

WARRANT
REQUIREMENT
PARTICULARITY
The warrant must
describe the person or
the place to be
searched and the
items to be seized
with particularity.
“the requirement that warrants shall
particularly describe the things to be
seized prevents the seizure of one thing
under a warrant describing another. As
to what is to be taken, nothing is left to
the discretion of the officer executing
the warrant” (Marron v. United States)

Probable cause is supplied by evidence which would
lead a reasonable person to believe that an offense
has been or is being committed or that the items to
which a search warrant is directed are located in the
area described.
WARRANT REQUIREMENT
PROBABLE CAUSE:

Staleness: An affidavit for a search warrant must
present timely information, and the warrant must be
promptly executed.
WARRANT REQUIREMENT
STALENESS:

Daytime 0600-2000
(95% of warrants will fall in this category)
Nighttime 2000-0600
Destruction of evidence
supporting facts…dead end road, video surveillance, dogs,
lookouts, barricades, etc..
WARRANT REQUIREMENT
Normal hours of service

Knock and announce
20 second rule
No Knock
Officer Safety
supporting facts…known presence of weapons, violent
criminal history, knowledge of any threats towards police.
WARRANT REQUIREMENT
Type of Service

The courts have recognized that unique circumstances
may render a warrantless search nonetheless reasonable
so long as the search falls within one of the established
“exceptions to the warrant requirement”.
The burden of proof rests on the government to prove the
search was reasonable.
WARRANT REQUIREMENT

No Suspicion
Some or Mere Suspicion
Reasonable Suspicion R/S
Probable Cause P/C
Reasonable Certainty
Proof Beyond a Reasonable Doubt
LEVELS OF SUSPICION

 Some or Mere Suspicion
– The lowest level of suspicion. A subjective suspicion on
the part of an officer, i.e. a suspicion in his mind and
need not be based on any objectively articulable facts.
– May be as little as a “hunch” or based on facts which do
not support reasonable suspicion.
LEVELS OF SUSPICION

o Reasonable Suspicion
 Based on specific articulable facts which, when taken
together with what one can reasonably infer from those
facts, would lead a reasonable officer to suspect that a
person “might be” or have been engaged in criminal
activity.
LEVELS OF SUSPICION

DEMEANOUR OF SUSPECT1
GAIT AND MANNER2
PREVIOUS KNOWLEDGE OF
BACKGROUND OR
CHARACTER
3
FACTORS USED TO
DETERMINE
REASONABLE
SUSPICION
Courts have recognized the
following as factors used to
determine if an officer had
reasonable suspicion.
IF THEY ARE CARRYING
ANYTHING AND WHAT IS IT4

MANNER OF DRESS
INCLUDING BULGES IN CLOTHING
WHEN CONSIDERED IN LIGHT OF ALL
OTHER FACTORS
5
TIME OF DAY OR NIGHT
SUSPECT OBSERVED6
ANY OVERHEARD
CONVERSATIONS OF THE
SUSPECT
7
FACTORS USED TO
DETERMINE
REASONABLE
SUSPICION
reasonable suspicion. THE PARTICULAR
STREET AND AREAS
INVOLVED
8

ANY INFORMATION
RECEIVED FROM 3RD
PERSONS (KNOWN OR
UNKNOWN)
9
IS SUSPECT CONSORTING
WITH THOSE WHOSE
CONDUCT IS REASONABLY
SUSPECT?
10
PROXIMITY TO KNOWN
CRIMINAL CONDUCT
11
FACTORS USED TO
DETERMINE
REASONABLE
SUSPICION
INCIDENCE OF CRIME IN THE
IMMEDIATE NEIGHBORHOOD12

SUSPECTS APPARENT
EFFORTS TO CONCEAL AN
ARTICLE
13
APPARENT EFFORT OF THE
SUSPECT TO AVOID
IDENTIFICATION OR
CONFRONTATION BY THE
POLICE
14
FACTORS USED TO
DETERMINE
REASONABLE
SUSPICION

 Probable Cause
 Means evidence which would lead a reasonable person
to believe that an offense has been or is being committed
or that objects subject to seizure are in the place to be
searched.
LEVELS OF SUSPICION

EXCEPTIONS
Searches without a
warrant must fall in to one
of the recognized
exceptions to the warrant
requirement for the
search to be held valid.

Search Incident
to Arrest
Consent
Plain
View/Smell/Feel
Abandonment
Automobile
Exception
Inventory
Probation/Parole
Pat downs/
protective
sweeps/Terry
“search”
Exigent
Circumstances

EXIGENT CIRCUMSTANCES
EXCEPTIONS TO THE WARRANT
REQUIREMENT

There are essentially six scenarios that justify a warrantless entry into a residence:
RESCUE
DESTRUCTION OF
EVIDENCE
PROPERTY
DAMAGE
HOT PURSUIT
PUBLIC DANGER
PREVENT ESCAPE

14.3
ARKANSAS RULES OF CRIMINAL
PROCEDURE
An officer who has reasonable cause to believe that premises or a vehicle contain:
(a) individuals in imminent danger of death or serious bodily harm; or
(b) things imminently likely to burn, explode, or otherwise cause death, serious bodily
harm, or substantial destruction of property; or
(c) things subject to seizure which will cause or be used to cause death or serious bodily
harm if their seizure is delayed;
may, without a search warrant, enter and search such premises and vehicles, and the
persons therein, to the extent reasonably necessary for the prevention of such death,
bodily harm, or destruction.

 Requirements
 Immediate Action
 Exigent Circumstances
 Homicide Scene
 Limited Search
 Creation of exigent circumstances by police

 Factors to be considered:
1. The commission of grave offense
2. Belief that suspect is armed
3. A clear showing of probable cause to believe the suspect
committed the crime
4. Strong reason to believe the suspect is in the premises
being entered
5. Likelihood that the suspect will escape if not swiftly
apprehended
6. The danger of destruction of evidence

SEARCH INCIDENT TO ARREST
EXCEPTIONS TO THE WARRANT REQUIREMENT

 Search incident to (custodial) arrest
– Incident to a lawful arrest, an officer may:
 Conduct a full search of the arrestee; and
 Articles in his possession; and
 The area within the arrestee’s immediate control.

FOR THE
PURPOSE OF
DISCOVERING
EVIDENCE
WEAPONS
MEANS OF ESCAPE
W E E

12.2
ARKANSAS RULES OF CRIMINAL PROCEDURE
An officer making an arrest and the authorized officials at the police
station or other place of detention to which the accused is brought
may conduct a search of the accused's garments and personal
effects ready to hand, the surface of his body, and the area within his
immediate control.

12.2
– Permissible purposes.
 (a) to protect the officer, the accused, or others;
 (b) to prevent the escape of the accused;
 (c) to furnish appropriate custodial care if the accused is
jailed; or
 (d) to obtain evidence of the commission of the offense
for which the accused has been arrested or to seize
contraband, the fruits of crime, or other things criminally
possessed or used in conjunction with the offense.

ARIZONA v. GANT
(US Supreme Court 2009)
– Police may search the passenger compartment of a vehicle
incident to a recent occupant's arrest only if it is reasonable to
believe that the arrestee might access the vehicle at the time
of the search OR that the vehicle contains evidence of the
offense of arrest.

PRETEXTUAL
ARREST
Making a lawful arrest of a suspect because of your desire to search
their person, their car, or their belongings.
Legal?

SEARCH
& SEIZURE
Fourth Amendment protection — compared with protection
afforded by Arkansas Constitution.
“There are occasions and contexts in which federal Fourth
Amendment interpretation provides adequate protections
against unreasonable law enforcement conduct; however,
there are also occasions when the Arkansas Supreme
Court will provide more protection under the Arkansas
Constitution than that provided by the federal courts.”

SEARCH INCIDENT TO
ARREST “BUT FOR…”
TEST
STATE of Arkansas, Appellant v. Kenneth Andrew SULLIVAN,
Appellee No. CR 99-1140 Supreme Court of Arkansas
348 Ark. 647; 74 S.W.3d 215; 2002 Ark. LEXIS 295
Opinion Delivered May 16, 2002.
Would the arrest
have occurred “but
for” the officers
desire to search?

SEARCH
INCIDENT TO
ARREST
“BUT FOR…”
TEST
YES
The arrest is
NOT deemed
pretextual and
the search is
valid.
NO
The arrest is
deemed
pretextual and
the search is
invalid.

IF A PERSON CONSENTS TO A SEARCH, THERE ARE NO
FOURTH AMENDMENT PROTECTIONS.
Consent searches are the most common form of warrantless searches. A
search warrant or probable cause is not necessary if consent is given by
someone with proper authority.
Citizens have a right granted by the fourth amendment to be free from
“unreasonable searches and seizures.”
They also have a right to voluntarily waive those protections.
CONSENT SEARCH

United States v Drayton (153 L Ed 2d 242 (2002) U.S. Supreme Court)
Officers do not violate the Fourth Amendment merely by approaching individuals in public
places and putting questions to individuals, if they are willing to listen.
Even when officers have no basis for suspecting a particular individual, they may pose
questions, ask for identification, and request to consent to search their person or property,
provided they do not induce cooperation by coercive means.
If a reasonable person would feel free to terminate the encounter, then he has not been
seized for purposes of the Fourth Amendment.
***Officers do not need to advise people of their right to refuse to cooperate.***
(with some exceptions we will discuss)
CONSENT SEARCH

EXCEPTION TO THE WARRANT REQUIREMENT
CONSENT SEARCH IS LAWFUL IF…
THERE IS VOLUNTARY
PERMISSION GIVEN TO
SEARCH (CONSENT NOT
COERCED)
1
GIVEN BY A PERSON
WITH REAL OR
APPARENT AUTHORITY
2
SEARCH CONFINED TO
THE SCOPE OF THE
CONSENT
3 RIGHT TO REVOKE
CONSENT4

CONSENT TO SEARCH?
What can people consent to have searched?
CARS1
DATA4
PERSON2
RESIDENCE
( KNOCK AND
TALK )
5
PROPERTY3
ANYTHING
WHERE THERE
EXISTS A
R.E.O.P.
6

11.1
(a) An officer may conduct searches and make
seizures without a search warrant or other color of
authority if consent is given to the search.
(b) The state has the burden of proving by clear
and positive evidence that consent to a search was
freely and voluntarily given and that there was no
actual or implied duress or coercion.

11.1
(c) A search of a dwelling based on consent shall not be
valid under this rule unless the person giving the
consent was advised of the right to refuse consent.
For purposes of this subsection, a "dwelling" means a
building or other structure where any person lives or
which is customarily used for overnight accommodation
of persons. Each unit of a structure divided into
separately occupied units is itself a dwelling.

ARKANSAS RULES OF CRIMINAL PROCEDURE 11.2
PERSONS FROM WHOM EFFECTIVE CONSENT MAY BE
OBTAINED?
(a) search of an individual's person, by the individual in question or,
if the person is under fourteen (14) years of age, by both the
individual and his parent, guardian, or a person in loco parentis;
(b) search of a vehicle, by the person registered as its owner or in
apparent control of its operation or contents at the time consent is
given; and
(c) search of premises, by a person who, by ownership or
otherwise, is apparently entitled to give or withhold consent.

CONSENT RESIDENCE SEARCH
Roommates
Common Areas
Married
Couples
Kid’s Room
Rented Rooms
Out Buildings (area
of control or access)
Apartments
(management)
Hotel Rooms
(abandonment)

TRAFFIC
STOP
CONSENT
o Number of Officers present
o When consent obtained
o Weapons displayed?
o Passengers Belongings?
o Informed of right to refuse?
Things to consider

PLAIN
VIEW/SMELL
The plain view exception applies when:
The law enforcement officer did not violate the
Fourth Amendment in arriving at the place
where the evidence could be plainly viewed; &
The item is in plain
view
The incriminating character of the
evidence is immediately apparent.

PLAIN VIEW DURING EXIGENT
CIRCUMSTANCES
GET A WARRANT
BEFORE GOING BACK

I’ve never
seen that
before.
ABANDONMENT
Not my bag
over there!
These
aren’t my
pants.
I didn’t
drop that.

ABANDONMENT EXCEPTION
A person who voluntarily abandons his property no longer
retains any reasonable expectation of privacy in that property.
Clarify abandonment. Ask the person if the item is theirs. If they
deny ownership, and you saw them in possession, they have
voluntarily abandoned the item.

ABANDONMENT
TRASH
As long as the officer did not violate the curtilage to
recover the trash it is considered to be abandoned.
NO REASONABLE
EXPECTATION OF PRIVACY
IN TRASH THAT HAS BEEN
DISCARDED (ABANDONED)
OR PLACED AT THE CURB
FOR COLLECTION
Rickard v.
State, 354 Ark.
345 (2003)

VEHICLE EXCEPTION
First established by S.C.O.T.U.S. in 1925
Carroll v United States 267 U.S. 132 (1925)
When officers have probable cause to believe that an automobile
contains contraband, the Fourth Amendment does not require
them to obtain a warrant prior to searching the car for and
seizing the contraband..

VEHICLE EXCEPTION
An officer may conduct a warrantless search of a mobile
conveyance if:
There is probable cause to search, and
The conveyance is mobile or readily mobile.

VEHICLE EXCEPTION
Rationale:
Lesser expectation of privacy
Mobility
Vehicles include:
Boats
Camper Trailers
Aircraft
Trains
Tractor Trailers
Motor Homes

14.1
(a) An officer who has reasonable cause to believe that a moving or readily
movable vehicle is or contains things subject to seizure may, without a
search warrant, stop, detain, and search the vehicle and may seize things
subject to seizure discovered in the course of the search where the vehicle
is:
(i) on a public way or waters or other area open to the public;
(ii) in a private area unlawfully entered by the vehicle; or
(iii) in a private area lawfully entered by the vehicle, provided that exigent
circumstances require immediate detention, search, and seizure to prevent
destruction or removal of the things subject to seizure.

14.1
(b) If the officer does not find the things subject to seizure by his search of
the vehicle, and if:
(i) the things subject to seizure are of such a size and nature that they could
be concealed on the person; and
(ii) the officer has reason to suspect that one (1) or more of the occupants of
the vehicle may have the things subject to seizure so concealed;
the officer may search the suspected occupants; provided that this
subsection shall not apply to individuals traveling as passengers in a vehicle
operating as a common carrier.

SCOPE OF PC SEARCH VEHICLE EXCEPTION
The scope of the search is limited to only what area the
officer has probable cause to search. This area can
encompass the entire vehicle including the trunk. The
motor vehicle exception in addition to allowing officers to
search the vehicle also allows officers to search any
containers found inside the vehicle that could contain the
evidence or contraband being searched for.

VEHICLE
EXCEPTION
AND THE
POLICE K9

K9
SNIFF
K9 Sniff is NOT a SEARCH by the
meaning of the 4th Amendment. Because
there is “no reasonable expectation of
privacy to the air surrounding ones
vehicle.”
An alert by a trained, certified, and reliable K9 provides probable cause (probable cause
allows a search under the vehicle exception)

K9 SNIFF
TIMING IS
EVERYTHING
No reasonable
suspicion is required
to conduct a K9 sniff
of a vehicle during the
“normal business” of
the stop.
After “normal business” has
been completed reasonable
suspicion is required to extend
the detention (SEIZURE) of the
motorist for the purpose of
conducting a K9 sniff.

INVENTORY
ADMINISTRATIVE
FUNCTION

INVENTORY TO PROTECT PROPERTY
Inventory procedures are constitutional under the Fourth
Amendment because they serve to protect an owner’s
property while it is in the custody of the police, to insure
against claims of lost, stolen or vandalized property, and to
guard the police from danger.
An inventory search is valid if:
 A lawful basis for taking custody of the property exists;
 The inventory is conducted in accordance with
standardized criteria limited to the purposes for inventory
searches.

INVENTORY TO PROTECT PROPERTY
Ark. Rule of Crim. Pro. 12.6
Department Policies
Search of Containers

PROBATION
PAROLE /
SEARCH
EXCEPTION
UNITED
STATES V
KNIGHTS
534 U. S.
112 (2001)
U. S.
SUPREME
COURT
You may conduct a
warrantless search of
a person, his
property, residence,
vehicle and personal
effects, supported by
reasonable suspicion
and authorized by a
probation condition.

BORDER
SEARCH
Automotive travelers may be stopped at fixed checkpoints near the
border without individualized suspicion, even if the stop is based
largely on ethnicity, and boats on inland waters with ready access to
the sea may be hailed and boarded with no suspicion whatsoever.
Routine searches of persons
and effects of entrants are
not subject to any
requirement of reasonable
suspicion, probable cause or
warrant.

PROTECTIVE SWEEP
In the course of
conducting a lawful
search or arrest within
a building, officers may
make a quick
“protective sweep” of
the premises if: There is R/S
based on
articulable facts
that others are on
the premises who
may be a threat;.
REASONABLE
SUSPICION
The sweep is
limited to areas,
locations, and
places where a
person could be,
and…
LIMITED
SCOPE
The sweep is not
a pretext to
search for
evidence.
NOT A
PRETEXT

TERRY
SEARCH
INVESTIGATIVE
DETENTION

TERRY SEARCH
Police may stop/detain a person based upon reasonable
suspicion that a crime
has been, is being, or is about to be committed
and conduct a frisk of the
outer clothing for the purpose of discovering dangerous
weapons.

3.4
If a law enforcement officer who has detained a person
under Rule 3.1 reasonably suspects that the person is
armed and presently dangerous to the officer or others, the
officer or someone designated by him may search the outer
clothing of such person and the immediate surroundings
for, and seize, any weapon or other dangerous thing which
may be used against the officer or others.
In no event shall this search be more extensive than is
reasonably necessary to ensure the safety of the officer or
others.

TERRY SEARCH (PAT DOWN)
Two requirements:
Lawful contact
Reasonable suspicion
Limitations:
Pat down of outer clothing only
Search only for weapons, not for evidence of
crimes

PLAIN FEEL
You can only remove items such as
contraband in a Terry Search if it is
“readily apparent”
You cannot manipulate an item to discover
what it is.

FRISKS:
TO SEIZE OR NOT TO SEIZE
Are there articulable facts
demonstrating objectively reasonable
suspicion that person is presently armed
with a potential weapon?
YES or NO?

FRISKS:
YES
Conduct a protective
frisk strictly limited to
that necessary to
discover weapons.
NO
No frisk permissible

FRISKS:
Does the officer reasonably believe that item
detected during frisk could be a weapon?
YES or NO?

FRISKS:
YES
Remove object
NO
Continued
searching not
authorized

FRISKS:
During frisk, does officer see/feel an object
that is immediately recognized as evidence?
YES or NO?

WINGSPAN SEARCH:
TERRY SEARCH OF AUTO
Michigan v. Long 392 U.S. 1032 (1983)
“…the search of the passenger compartment of an
automobile, limited to those areas in which a weapon
may be placed or hidden, is permissible if the police
officer possesses a reasonable belief that the suspect
is dangerous and the suspect may gain immediate
control of weapons.

WINGSPAN SEARCH: TERRY SEARCH OF AUTO
The court gave 3 reasons for its holding…
THE SUSPECT MAY
CONCEIVABLY
BREAK AWAY
FROM POLICE
CONTROL AND
RETRIEVE A
WEAPON.
IF THE SUSPECT IS NOT
PLACED UNDER ARREST,
HE WILL EVENTUALLY BE
PERMITTED TO REENTER
HIS CAR WHERE HE WILL
THEN HAVE ACCESS TO
ANY WEAPONS THAT MAY
BE INSIDE AND
EVEN DURING THE
COURSE OF THE
DETENTION, THE
SUSPECT MAY BE
ALLOWED TO REENTER
THE CAR BEFORE THE
INVESTIGATIVE
DETENTION IS
CONCLUDED.

IMPORTANT CASES
Whren v United States
517 U.S. 806, 135 L. Ed. 2d 89 (1996)
A traffic stop was permissible – regardless of
whether a police officer subjectively believed that the
occupants of an automobile might be engaging in
some other illegal behavior – as long as a reasonable
officer in the same circumstances “could have”
stopped the car for the suspected traffic violation.

IMPORTANT CASES
Miranda v. Arizona 384 U.S. 436 (1966)
Fifth amendment / Self Incrimination
When is Miranda warning required.

QUESTIONS? CAN THE POLICE…
Can police order the driver of a
lawfully stopped car out of the vehicle
during a traffic stop?

IMPORTANT CASES
Pennsylvania v. Mimms
434 U.S., at 111, n. 6.
In Mimms, the Court held that “once a motor vehicle
has been lawfully detained for a traffic violation, the
police officers may order the driver to get out of the
vehicle without violating the Fourth Amendment’s
proscription of unreasonable searches and seizures.”

Can police order the passenger of a
lawfully stopped car out of the vehicle
during a traffic stop?

IMPORTANT CASES
Maryland v. Wilson
519 U.S. at 415
Wilson held that the Mimms rule applied to
passengers as well as to drivers. Specifically, the
Court instructed that “an officer making a traffic stop
may order passengers to get out of the car pending
completion of the stop.”

Can police request identification from
a passenger in a lawfully stopped
vehicle?

Can you compel a passenger in a
lawfully stopped vehicle to provide
identification?
If yes, when?
If no, what are your options?

Introduction to 4th search and seizure Arkansas

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