concluding that the officers acted reasonably in arresting a person who was in the apartment and fit the general description of a suspect for whom they had probable cause to arrest, and affirming the principle that “[w]hen the police have probable cause to arrest one party, and when they reasonably mistake a second party for the first party, then the arrest of the second party is a valid arrest” (alteration in original) (internal quotation marks omitted)
How later courts described this case
- concluding that the officers acted reasonably in arresting a person who was in the apartment and fit the general description of a suspect for whom they had probable cause to arrest, and affirming the principle that “[w]hen the police have probable cause to arrest one party, and when they reasonably mistake a second party for the first party, then the arrest of the second party is a valid arrest” (alteration in original) (internal quotation marks omitted)
- holding that arrest of person not named in warrant due to an understandable mistake of identity and the subsequent search did not violate the Fourth Amendment because the arrest and search were "reasonable response[s] to the situation facing [the officers] at the time"
- finding that “sufficient probability, not certainty, is the touchstone of reasonableness under the Fourth Amendment and on the record before us the officers’ mistake was understandable and the arrest a reasonable response to the situation facing them at the time.”
- holding that police were reasonable in believing that the person whom they arrested was a robbery suspect whom they had probable cause to arrest, and, therefore, search incident to that arrest was reasonable under the fourth amendment
Written by the judges who cited it.
Distinguished
Distinguished by Pierce v. Cnty. of Marin, 291 F. Supp. 3d 982 (2018)
The Court finds that Hill is distinguishable from the facts alleged in this case, and that plaintiff has stated a claim.
Distinguished by People v. Nimmons, 60 A.D.2d 129 (1977)
Understandably, defendant urges that Hill is readily distinguishable.
The opinion
Mr. Justice Harlan,
whom Mr. Justice Marshall joins, concurring in part and dissenting in part.
I agree with the Court’s opinion except for its conclusion that the Chimel case is not to be applied to this one.
Two Terms ago, in Chimel v. California, 395 U. S. 752 (1969), we held that a search without a warrant, but incident to a lawful arrest, must be narrowly confined in scope if it is to pass constitutional muster. In such circumstances, we said:
“There is ample justification ... for a search of the arrestee’s person and the area ‘within his immediate control’ — construing that phrase to mean the area from within which he might gain possession of a weapon or destructible evidence.
“There is no comparable justification, however, for routinely searching any room other than that in which an arrest occurs — or, for that matter, for searching through all the desk drawers or other closed or concealed areas in that room itself. Such searches, in the absence of well-recognized exceptions, may be made only under the authority of a search warrant. The ‘adherence to judicial processes’ mandated by the Fourth Amendment requires no less.” 395 U. S., at 763 (footnote omitted).
*807 The search here involved, fully described in the Court’s opinion, plainly exceeded the bounds set forth in Chimel . The State contends that the search here was consistent with Chimel because conducted in the evening when it was not possible to obtain a search warrant. Whatever validity such a limiting principle might have in other contexts, it certainly cannot properly be invoked here. Baum and Bader had implicated Hill at least 24 hours prior to the search of Hill’s apartment. Moreover, the State does not explain why it would not have been possible to observe the apartment after the mistaken arrest of Miller as Hill and then test before a magistrate the validity of their belief that they had probable cause for the issuance of a warrant authorizing a complete search of the apartment.
Because I believe this case reveals an obvious violation of Chimel and because I consider we are duty bound to apply the principles there enunciated to cases, like this one, before us on direct review, see my separate opinion in Mackey v. United States (and companion cases), ante, p. 675, decided today, I am compelled to cast my vote for reversal of the judgment of the Supreme Court of California.