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Law School Case Brief

Adams v. Williams - 407 U.S. 143, 92 S. Ct. 1921 (1972)


A police officer may in appropriate circumstances and in an appropriate manner approach a person for purposes of investigating possibly criminal behavior even though there is no probable cause to make an arrest. The Fourth Amendment does not require a policeman who lacks the precise level of information necessary for probable cause to arrest to simply shrug his shoulders and allow a crime to occur or a criminal to escape. A brief stop of a suspicious individual, in order to determine his identity or to maintain the status quo momentarily while obtaining more information, may be most reasonable in light of the facts known to the officer at the time.


In the wee hours of the morning, while a police officer was alone on patrol, a person known to him came to his patrol car and informed him that an individual seated in a nearby car was carrying narcotics and had a gun at his waist. After calling for assistance, the police officer approached the nearby car, tapped on the car window and asked the respondent, who was the occupant of the car, to open the door. Instead, the respondent rolled down the window, and the officer reached into the car and removed from the respondent's waistband a loaded revolver. The officer arrested the respondent for unlawful possession of the revolver, and for possession of heroin, which was found in the car. The state trial court judge admitted the items into evidence, and the respondent was convicted. After the Connecticut Supreme Court affirmed his conviction and the United States Supreme Court denied certiorari, he instituted habeas corpus proceedings in the federal district court The District Court denied relief and the United States Court of Appeals for the Second Circuit initially affirmed, but the Court of Appeals later reversed, on rehearing en banc, and held that since the officer had neither probable cause to arrest the respondent nor any other sufficient cause for reaching into his waistband, the evidence seized was improperly admitted at the respondent's trial, and the respondent's conviction had to be set aside. The warden petitioned for certiorari review by the United States Supreme Court.


Does the search of respondent’s car violate his rights under the Fourth Amendment?




The United States Supreme Court reversed, ruling that the information carried enough indicia of reliability to justify the stop of respondent. From that, the Court ruled that the officer, having a reasonable belief that respondent was armed and dangerous, made a permissible limited protective search for the weapon at respondent's waist, despite the fact that the weapon was not visible from the exterior of the car. Having seized the weapon, the officer was provided with probable cause to arrest respondent for its possession; the subsequent search incident to arrest, which produced the narcotics that formed the basis for respondent's heroin conviction, was therefore lawful.

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