Law School Case Brief
Hayes v. Florida - 470 U.S. 811, 105 S. Ct. 1643 (1985)
Seizures made when the police, without probable cause or a warrant, forcibly remove a person from his home or other place in which he is entitled to be and transport him to the police station, where he is detained, although briefly, for investigative purposes, at least where not under judicial supervision, are sufficiently like arrests to invoke the traditional rule that arrests may constitutionally be made only on probable cause.
Defendant Joe Hayes, considered to be a principal suspect in a burglary-rape in Punta Gorda, Florida, was transported by police from his home to the police station for fingerprinting without his consent and without probable cause or prior judicial authorization. Defendant was placed under arrest when it was determined that his fingerprints matched those left at the scene of the crime. A pretrial motion to suppress the fingerprint evidence was denied and defendant was subsequently convicted of the charges. Although finding neither consent by defendant to be taken to the station nor probable cause to arrest,the Florida District Court of Appeal affirmed the conviction, holding that the police could transport defendant to the station house and take his fingerprints on the basis of their reasonable suspicion that he was involved in the crime. The United States Supreme Court granted defendant's petition for certiorari review.
Did the investigative detention for fingerprinting purposes violate a defendant’s rights under the Fourth Amendment?
The Court held that police officers acting without probable cause and without a warrant violated the Fourth Amendment, made applicable to the states by the Fourteenth Amendment, by forcibly removing a person from his home or other place where he was entitled to be and transporting him to the police station for fingerprinting. According to the Court, fingerprints taken under these circumstances were the inadmissible fruits of an illegal detention. As such, the Court reversed the judgment of the district court, averring that defendant had been detained involuntarily, and the fingerprint was obtained as the result of such involuntary detention.
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