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  • Law School Case Brief

Beck v. Ohio - 379 U.S. 89, 85 S. Ct. 223 (1964)

Rule:

Whether an arrest is constitutionally valid depends in turn upon whether, at the moment the arrest is made, the officers have probable cause to make it - whether at that moment the facts and circumstances within their knowledge and of which they have reasonably trustworthy information are sufficient to warrant a prudent man in believing that the suspect has committed or is committing an offense. The rule of probable cause is a practical, nontechnical conception affording the best compromise that has been found for accommodating often opposing interests. Requiring more would unduly hamper law enforcement. To allow less would be to leave law-abiding citizens at the mercy of the officers' whim or caprice.

Facts:

Police officers, who had received unspecified "information" and "reports" about William Beck, who knew what he looked like, and that he had a gambling record, stopped Beck who was driving an automobile. Placing him under arrest, they searched his car, though they had no arrest or search warrant. They found nothing of interest. They took him to a police station, where they found some clearing house slips on his person, for the possession of which he was subsequently tried. His motion to suppress the slips as seized in violation of the Fourth and Fourteenth Amendments was overruled, the slips were admitted into evidence, and he was convicted, his conviction being ultimately sustained on appeal by the Supreme Court of Ohio, which found the search valid as incident to a lawful arrest.

Issue:

Were the search for and seizure of the slips valid?

Answer:

No

Conclusion:

The Court found that the arresting officers did not provide any testimony that gave probable cause to support the arrest of Beck. Furthermore, there was no evidence that the officers believed that Beck had acted or was acting unlawfully when he was arrested. The Court held that Beck’s arrest violated the Fourth and Fourteenth Amendments; therefore, the slips obtained as a result of the illegal arrest were inadmissible.

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