The standard of probable cause applies to all arrests, without the need to "balance" the interests and circumstances involved in particular situations. If an officer has probable cause to believe that an individual has committed even a very minor criminal offense in his presence, he may, without violating the Fourth Amendment, arrest the offender.
Petitioner was driving a pickup truck without wearing a seatbelt with her 3-year-old son and 5-year-old daughter, who were also unsecured by seatbelts in the front seat. The respondent police officer pulled her over and consequently arrested her. Thereafter, petitioner sued the arresting officer, the city, and the city's chief of police for violating her right to be free from unreasonable seizures. The defendants removed the suit to the United States District Court for the Western District of Texas, which granted summary judgment for the defendants. On appeal, a panel of the United States Court of Appeals for the Fifth Circuit reversed the decision and concluded that an arrest for a first-time seatbelt offense was an unreasonable seizure within the meaning of the Fourth Amendment. However, the Court of Appeals, in vacating the panel's decision in banc and affirming the District Court's judgment, reasoned that it was undisputed that the officer had had probable cause to arrest the driver, and that there was no evidence in the record that the officer had conducted the arrest in an extraordinary manner unusually harmful to the driver's privacy interests.
Did the arrest amount to a violation of unlawful seizure?
The Court determined that the Fourth Amendment does not limit police officers' authority to arrest without warrant for minor criminal offenses. In the case at bar, the respondent officer had probable cause to believe that petitioner arrestee had committed a crime in his presence; therefore, respondent officer was authorized to make a custodial arrest without balancing costs and benefits or determining whether or not the arrest was in some sense necessary. The Court rejected petitioners' argument that peace officers' authority to make warrantless arrests for misdemeanors was restricted at common law to instances of breach of the peace.