Law School Case Brief
Ornelas v. United States - 517 U.S. 690, 116 S. Ct. 1657 (1996)
The principal components of a determination of reasonable suspicion or probable cause will be the events which occurred leading up to the stop or search, and then the decision whether these historical facts, viewed from the standpoint of an objectively reasonable police officer, amount to reasonable suspicion or to probable cause. The first part of the analysis involves only a determination of historical facts, but the second is a mixed question of law and fact: The historical facts are admitted or established, the rule of law is undisputed, and the issue is whether the facts satisfy the relevant statutory or constitutional standard, or to put it another way, whether the rule of law as applied to the established facts is or is not violated.
In 1992, a police officer in Milwaukee, Wisconsin, approached a 1981 two-door Oldsmobile with California license plates in a motel parking lot and asked defendants Saul Ornelas and Ismael Ornelas-Ledesma, who were inside the car, whether they had any illegal drugs or contraband. The car was arguably characteristic of one typically used by drug couriers. Defendants said they did not have any illegal drugs or contraband, but they consented to a search of the car. A second officer, conducting the search without having obtained a warrant, discovered cocaine inside an interior panel. Defendants were arrested on drug charges and pleaded guilty in federal district court to possession of cocaine with intent to distribute. Nevertheless, in pretrial motions to suppress the cocaine evidence, it was alleged that the officers had violated defendants' rights under the Fourth Amendment by detaining them in the parking lot and by searching inside the panel without a warrant. A magistrate judge concluded that the circumstances had given the officers reasonable suspicion to stop and question defendants, but not probable cause to conduct a warrantless search. Adopting the magistrate judge's recommendation with respect to reasonable suspicion, but not the reasoning as to probable cause, the United States District Court for the Eastern District of Wisconsin ruled that the cocaine need not be excluded and defendants were convicted. On appeal, the United States Court of Appeals for the Seventh Circuit, reviewing deferentially the district court's determinations of reasonable suspicion and probable cause, found no clear error in the reasonable-suspicion analysis and affirmed that determination. It noted that the district court's determinations would be reversed only upon a finding of "clear error." However, the court vacated the district court's judgments of conviction and remanded the case for a determination as to probable cause. On remand, the district court ruled that probable cause supported the search. On appeal, the court affirmed, finding that the district court' determination was not clearly erroneous.
Did the appellate court properly affirm the district's judgment based on a standard that the decision was not clearly erroneous?
The Supreme Court of the United States vacated the judgment and remanded the matter to the intermediate appellate court to review de novo the district court's determinations that the officer had reasonable suspicion and probable cause. As a general matter, the Court ruled, for purposes of the Fourth Amendment, whether law enforcement officers had reasonable suspicion to stop persons and probable cause to make a warrantless search should be reviewed de novo, rather than "deferentially" and "for clear error."
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