Brief in Opposition to Petition for Writ of Certiorari — Wood v. Idaho

. ° . * ; ; °

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IN THE SUPREME COURT | eile 3:

i’ ae

| of the, wR Q

* UNITED STATES —_ |

NER.

: é E . £.. aekt se*

* October Term, 1971 :

No. 71-836 :

ARTHUR ROMUALD DESCHAMPS, III

- o “and ‘ ° he® al i >

RANDOLPH DOUGLAS WOOD | 5;

Petitioners — :

© - yr . j iz

STATE OF IDAHO.

Respondent

*

<

BRIEF. IN OPPOSITION TO PETITION

‘FOR WRIT OR CERTIORARI —

: KIDWELL, McKEE, cule -¢ tonnage eg FS

. Suite 414 Simplot Building.

Boise, Idaho 83701

Attorneys for Petitioners Raabe 6 ‘

a

~

_W. ANTHONY PARK

Attorney General

State of Idaho

Statehouse, Boise, Idaho 83797 .- -

Attorney ‘for Respondent

aot cae INDEX

Reasons for Denying the Writ ....0...6.0e8- 1

“

CASES CITED

United States v. AyeTS o..seeeeeetees vase: | 6¢

426. F2d 524

(2d Cir. 1970)

Coleman v.. United St ates ere PPP eee Ee

: ¢

420 F2d 616 Be tae A ie oe 5

(D.C. Cir. 1969) . =.

Ojeda v. Supersor Court, In ant Ye. °

County of Monterey ......seeeeeeeeee? op os “

9] Cal.Rptr. 145

12 Cal.App.3d 909 (197 0)-

:

‘State v. WOVE cnc cissseodecesccus See ene ee

92 Idaho 20

435 P.2d 797 (1967)

Whiteley v. Warden, Wyoming State

Penitentiary ....... CARED e Cap haves eee 7

U.S. .

28.L.Ed.2d 306

91 S.ct. 1031 (1971)

6

Aguilar v. Texas ..... ewes ea cea eee <aneus 12

378 U.S. 108

12 LEd.2d 725

"84 §.Ct. 1509 (1964)

Chamber v. Maroney .....-e-seees cece

399 US. 42 . iy

26 L.Ed. 2d 419 | es

90 S.Ct. 1975 (1970)

IN. THE SUPREME COURT.

of the

UNITED STATES

‘October Term, 1971

No. 71l- 836

e —

ARTHUR ROMUALD DESCHAMPS, III

and :

' ” RANDOLPH DOUGLAS. WOOD

Petitioners

is . V .

STATE OF IDAH@ ~

‘ Respondent |

BRIEF IN OPPOSITION TO PETITION -

FOR WRIT OR CERTIORARI

‘2 ~: - Resbondent,- ‘SFATE.QF. IDAHO, respectfully.

pam tHat. the Petition far Writ of Certiorari in

the ‘above entitled matter be, ,denied.

-RFASONS FOR DE ak BS THE WRIT

«

In this case the Petitioners raise the

i

question:-as to whether or not sufficient probable —

' —vause fdr the issuance of a search Warrant anc war-

rants for arrest exist thet the information supplied

to the Magistrate consists solely of ‘the. officer-

; affiant' S ‘statement that he received an All Points.

' Bulletin (APB) radio communication describing an

; automobile sigh two occupants belj ved to have mari-—

| juana- in their. possession and that he has picked up.

two men driving such an automobile. The reason Res-

pondent requests that the Petition for Writ of Certi-.

orari be. denied is simply that probable cause existed ©

- and justified. the actual arrest of -the Petitioners

upon the highway and aleo the subsequent issuance of

ea search warrant and warrant of arrest.

- The Petitioners’ rendition of the facts An this’

case begins somewhat belatedly. Pet itionérs. begin

with the receipt of an All Points Bulletin which led

to the arrest of the Petitionets herein. However,

“some. were significant instances occurred prior to

: the issuance of the All Point's Builetin in this case. |

s

2

_ The complaining witness, Ben Blinn, was a hitch-

hike rider in the. car driven by the Petitioners. Mr.

Blinn testified at’ lenth to the ‘inciderits which occur- °

red while hé was riding asa. hitchhiker in Petitioners’

automobile, Upori terminating his ride with the Pet i-

- tioners Mr. -Blinn testified that he: immediately pro-

| @

Se ode

¢

oa

ceeded to a telephone to contact the local police >

department and subseauently the Canyon County. Sheriff's

~Repartment. Immediately thereafter Mr. Blinn testi-

r

fied that séveral Sheriff's cars arrived on the’scene.

It was at this time that Mr. Blinn conveyed the, infor-

mation that Petitioners were *in possession of mari-.

‘unana and other drugs and that he delivered to the

-. authorities samples of the marijuana which he managed :

to apiiahieas while riding: with, Petitioners. , Mr. Blinn

also. gave a description | of ‘the’ Petitioners and of the’

vehicle which they were driving,” (Transcript page $4,

beginning at: tine. £0}:

se S gave the substance, which I-

believed to be marijuana, to the

officers and said that these.men of--

- fered me marijuana and: other drugs.

0 Did you give then ; a description‘

of the occupants of the automobile?

me gave them a sgcecie ee of the

individuals in the automobile, tHe

license number of the vehicle, the -

—description Of the veHicle, the color

* of. the vehicle and the location of.

‘where I believed the drugs: would

be in the vehicles. <

Q You gave that to: ‘the police Oar a

officers?: @. ps

ry “ . . \ ; \ .

@ : a a

-A I*gave that to the Sheriff." 3

oes ted his Arspat cher. and the Sheriff's “Office™at cald

* «6 i

-° —* ——s + ;

As a result oF this conversation with: Mx. Blinn,

“Deputy Skériff. Dean Edwards festified, at page 41 of

Late ArdinsH pe, eogcne—, nok line. 19, that he ipstruc- mn

sel, Idaho:. to put ‘oud a broadcast on: the police :

=e Fado’ transmitting the information prov; ded by Ben

Setters < the «dispatcher;-Russell Grbbin, testified at

page AB of the Transcript, “beginning at line-29, *

through page. 47 : line 24, ‘AS to the contents of the

. eet Points. ‘Bud letin which he pat out | over the air:

See At ten: fortyone a.m. T put, out. an. ‘all

_—. -*points bulletin to be on the watchout for -

-; “A 8 metallic green “edloréd,-196] Mercury

7 + station wagon with a “Montana license, Noel ak Ses

palling a ‘trailer, ‘U-Haul trailer with a -

. ‘motorcycle in it. The trailer had Wash-

~ ington Jicense on it and there. was two -

++ young feliows in the Se ee

=, Pe big it. ‘contain «ny other thane as ‘ie

to 2 what you, suspected or anything? . ‘What. ° ;

was in- = bulletin? _ FS

- - ‘

~~.

We aS MR. RYAN: He is Yeading the. wagness.

_ p> ‘The witnéss thas already answered the: —.

ha question as.to what he put out- and -we

would object: fae —

MRe JOSEPH: ~ I’ want” a ‘comp late report .

or 2 was not heading the-.witness,-

. . ¢ ~n ie aa : ° «*

“THE COURT: - I. am going to peamic the’ ee ee

witress his testimony as to what he .« . eccoe

| “at, Ba

F 3 - ; “i os :

—. ae 4

¥ e 3

o.-@

._. >

put out if he récalls hat he put

6 out. However., I am admonishing the

% Ju¥y at the same time that you are —

not to be considering this for the

truth. of the-matter at thjs point. .

\ He is testifying as to what. he did. zi

You may answer if you put out “ahything,

élse.- se,

; A I-did, Your Honor. After des- «’

‘ cribing the car and:the trailer

. 1t was put out that there were two

young -fellows in 1t and -that a

' Deputy and he had been offered

afd that this car was headed horth "

‘on Highway 95 at this time." -., -

At - ‘page 52 of the Transcript, “beginning at

hitchhiker talked to ‘our Chief . ce

line” 16, the dispatcher's testimony jis to the contents

of the All Points Bulletin Was stricken ner the Court

as not being the best evidence. available to the State

‘, necessary ta, ‘prove the contents of: the bulletin

_ However, the All Points: Bulletin was admitted into

“tevidence as State! s Exhibit. "1" at, page 59. of the

‘Transcript, line 4. or a ae

; In the present. case, the Respondent STATE

QF- IDAHO does nat rely solely upon the. APB broadcast

over the police -radio,- for it fs evident from the

record -that the subject matter- from-the APB was -tésti

"" fied to directly by the complaining _withess, ‘Ben

ye ——- t= |

.

/

marijuana and some kind of pills \

AY

s

_° Blinn, the informant. It was further.testifTéd to

by Deputy Sheriff Edwards; further téstimony, though —

not as to the subject matter of the Ail Pornts Bul

letin, was. received by the dispatcher himself, Rus -

‘sell Gibbin, all of’ whom are subject to cross exam ‘s

* ination by Petitioners’ counsel.

An, awareness of the: Rane: fagts which occur

red prior to where Petitioners’ statement of the* case

begins 18 extremely important ‘to any determination

in this case for the reason that a police communi

. cation will. satisfy the constitutional probable catse

requirement if it was issued with probable cause.

United States v. Ayers. 426° F2d 524 (2d Cir: 1970),.

€oleman v. United States, 420 -F2d 616 (D, C:Cir. 1969),

Ojeda’ v. Superior Court; In and For County Monterey,

+ 91 Cai,Rptr. 145,°12 Cal.App.3d' 909 (1970): In the.

_présent_ case, the information which precipitated the

issuance of the All Points “pul fetin yas supplied by -

a known and ident! fied informant who had personally.

" seen the marijuana in the possession of the Petiti-”

aS oners ‘and- who had given sampfes of this substance to ~

the authorities prior to the initiation of the APB.

- ° The’ Respondent , STATE’ OF DAD, company: that

‘at the time the Petitioners were ‘stopped and detained

Upon the highway, there was ‘in fact a legal arrest,

State. v.-Loyd, 92 Idaho 20, 435 -P.2d 797 Balt and -

.

“a

=e ra

based on. the -previously recited: facts, probable cause

———o-

= existed. tot justify.the legality of police conduct at

this‘point in time... — Sens eee rs .

Petitioners contend that: the case of

- Whiteley v. Warden, Wyoming Staté Penitentiary,

Usd. ee 2s L.Ed.2d 306, 91 S.Ct. 1031 (397 1), :

ee ane sy .

does not hold that an APB 7S ipso facto sufficient

probable cause hefore | a Magistrate. With this the

Respondent, STATE OF IDAHO, necessarily agrees. ties

pee Whiteley case. supra, concerned 2 sitiat ton where

3 "the. court ‘found the’ ifformation supporting the com-

“munication had been supplied by an undisclosed infor-

manty that it-was inadequate,” and that, the. ensuing

arrest on the strength of such communication was.

ee. without probable cause. However, the court also

. * ll

stated:

: "We do not of course question that

ar | ay -- the Laramie police were éntitied to

se . act on the strength of the radio bu!-

Soe .“letin.. Certainly police officers

eh eines - called upon.to aid other officers

; 1n executing arrest-warrants are a

entitled. to assume that the officers .

- requesting aid offered the magistrate -

the information requisite to support

an independent judicial assessment

of probable cause. Where,’ however’,

the contYary.turns out to be true,

- an otherwise illegal arrest cannot ofr ;

. be-insulated from challenge by the. -° - | i .

_ decision of the : ‘inst igat ing officer

tioners’ case, contrary to ‘the Whiteley case. supr

to rely on fellow officers to make the

arrest." Whiteley v. Warden, Wyoming

State Penitentiary - - U.S.

28 L.Ed.2d 306, 91 Ss. Ct.1031- (1971)-

,

in essence, then the ‘Respondent contends in

gustifying police comluct based upon an All Points .

Bulletin. there must be a retrospective justification

therefor’ and finding of-probable cause. In Pet. .

-_———

the informant was Known and disclosed to. the inyol.

ved authorities: ‘This informant not only” saw the

controlled substance in the possession of the Pet: -

; Lioners, * but he also related the possible ‘locatign

F

of the cont rolled substance and he rendered up to

*

authorities samples ‘of this controlled substance,

. . all prior to the is$uance of the Al, Points Bulletin.

Resfondent STATE OF IDAHO would therefore suggest

that it 1s not so much the §PB itself which provides

the probable cause to justify police procedure in

this case, but the facts themselves which gave rise

ae :

-. the All Points Bulletin which manifests’the pro

bable Cause and justified eee conduct...

‘Indeed, the Idako Supreme Court recognized this

?

supposition in, its decision rendered in Petitioners’

case-

~

-

-

.

See

. ‘

.

*

,

aa

.It is our conclusion that an

official police commynication dees

‘ provide probable cause for either -

purpose so long as the communication

eitself is based upon sufficient in-

formation -to constitute probable

cause. :

"Respondent. cites several recent cases

in-which..courts have found that .a

- police communication will satisfy -

P }

‘the constitutzdnal probable cause

requirément if 1t was issued with -.

probable cause. These, cases are:

United States v. Ayers, 426 F.2d -524

(2d-Cir. 1970}; Coleman v. United

States, 420 F.2d.616 (D.C.Cyr. 1969);

Ojeda v. “Superior Court “In and Por

County of° Monterey, 91 Cal. Rep. 145.,

12° Cal. App. 3d 909 (1970). In the

case at bar the information which ~

precipitated the issuance of the APB’

was. supplied by a known and identified. —

informant who had personaily seen the

‘Marijuana im tHe possession of the .

appellants. This previded a valid

basis. to issue the APB and established

probable cause for the subsequent

arrest and issuance of fhe search

warrant :

7

"Appellants cite Whiteley v. Warder,

Wyoming State Penitentiary, U.S.

» 91 S.Ct:1031, 28 L.Ed. 2d. 506 |

(971), as ‘supporting their contentior

‘that an.APB cannot supply probable

cause for a warrantless arrest unless

the arresting officer | knows the facts -

causing its issuance. We cannot ae.

. . : —

. That. Whiteley can be so interpreted. .

| case concerned, a situation where

the court found the information ‘sup,

porting the communication had been .

Supplied by an undisclosed informant,

that it was inadequate and that the’ -

ensuing arrest on the strength of:

such communication was without prob

able cause. However) the court also.

‘stated:

‘We do not of course question

that the Laramie police were

entitled to act on the strength

of the radio bulletin, Certainly

police officers called upon to

aid other officers in execut ing

arrest warrants are entitled to

assuge that the officers request

ing aN offered the. magistrate

-the infprmation requisite to

Support \an. independent judicial

- assessment of probable cause.

Where, however, -the contrary

‘turns out to be true; an other

wise illegal arrest cannot be‘

insulated from chatlenge by the

decision of the instigating

officer to rely on fellow officers

to make the arrest." U.S. . at

-

"Therefore. the United States Supreme Court

_ has not disturbed thosé decisions which |

hold that ‘there is probable cause for a

warrantless atrest on‘the basis of an

official police communication Supported

.by information itself reliable enough to

Supply probable cause. Furthermore the

conclusion to be reached from the above

Ener Pam

quoted langudge is that the cour’

has specifically-sanctioned such

‘ procedure.“ State v. Deschamps, °

et al, Idaho. Supreme Court Opin- nee

‘ions, Vol. 18, No. 84 (decided May -

Tern, caidas

a Petitioners particularly question whether *

or not probable. cause for the issuance of a search

warrant ahd warrant for arrest exist wheré the’ infor-

mation supplied. the magistrate consists solely of the

officer- iaadoenocl Ss statement that. he received an All

“Points ‘Bulletin- radio communication describing an

automobile with two ene believed to have ma

juana in tfeir’ possession and that he-has pickéd up

_ two men driving such an automobile. ‘In that ‘regard -

the Suprente Court of. the state: of Idaho made ‘the’ =

following comment : ena .

_. Appellants assert that the infor-

-smation contained in the- ‘unsupported APB

was the only evidence presented to the

probate judge to establish probable cause, .

and that it was. insufficient primarily

*because-it- wads based on hearsay. The- ~~

State. however, contends that the infor-

®mation initiating the APB was supplied

by_a hitch-hiker given a ride by apel-

lant, and this was also’ divulged to ;

the probate judge. eS a

x -& * . i 2s

"Since the APB ‘provided probable cause

for the warrantless arrest we find‘that

a ee as ; ai

*!

there was’ also probable cause for the-

isSuance by the probate judge of the.

search warrant and- subsequent ‘warrant

of arrest. At the pretrial conference

Probate Judge Henderson testified:

'Q. Well, I will withdraw that. _

question: Will yow tell The

-Court, if. you will, the whole

extent of the conversation that

: the sheriff revealed to you as

to any facts prior that he

revealed to you concerning this

thing in the all points bulfetin,

any ‘information he gave you

- “A, The peastins of-the mari-

Juana was ‘mentioned and that

the hitchhiker had told those

people, that there was marijuana

ets in pdsSession and ‘that the hitch-..

Vers hiker himself*had a marijuana ‘

with him and was possibly in

his shirt pocket, if ‘I remem- * |

ber correctly, *and he had a = ~*~ ——~——

‘pill in his shoe. Those two

Toe — struck me as odd.

Not paay did the probate judge have the

information inthe APB before him, which

_ we feel would have been sufficient, but

he Was also informed of the source of the

communication." State v. Degchamps; et-al’,

: Idaho Supreme’ Court Opinions, Vol.°18, No.

a -6a (May, Term, i971), Pa

*

What information, ‘then, ‘was provided Judge.

Henderson, ” enabling him to find the necessary. pro~

bable cause to issue the search warrant and.warrant

cad

e al

.

6f arrest? Judge Henderson testified, beginning at.

"page 4 of the ‘Transcript, that prior to issuing the

search entre he obtained a deposition of facts toe

sipport the warrant and an affidavit from the Sheriff

of Washington | County, and that he disciesed at some

length the APB containing the informat ich’ about the

ieaineks the Petitioners herein, and the fact that

the information contained, in the APB came from Ben-

Blinn, the informant hitchhiker. ‘Based on the ‘infor-

‘mation contained in.the APB, the deposition of facts: .

and the clarifying discussion with the Sheriff to the

effect th@t the inf formant had taken- marijuana from

the pet it@bners and given: it to the Sheriff (Tr..

12, L.16), Judge Henderson issued. the warrants. te

spondent STATE ‘OF IDAHO does: not deny that the infor-

mation supplied by. ‘the hitchhiker informant, Ben Blinn,

“was not contained in the affidavit or deposition of

* fects in, support of the search warrant, as. required

by Aguilar v. Texas, 378 U.S. 108, .12-L.Eds2d 143;

84 S. cc... 1509, “This, however, in the” Respondent!s.

‘opinion, “isonot- fatal toa the State of Idaho's case

against. the Petitioners. Respondent has previously

argued the ‘legality of the. ; probable: cause arrest °

which took: place when the Petitioners wére stopped

bar the tiginay- In brief and in oral argument befdre

the Honorable Supreme Court of the State of Idaho,

* 13,-:%

. Respondent contended that’ the arrest of Petitioners

was a‘ legal arrest and. justified apart from’ the sub-

sequent arrest warrants Respondent! contention

remains the same before ‘this Honorable Court; that |

is to say, regardless of any’ defectiveness in the

arrest warrant , the initial. confrontation between

the police and the Petitioners upon. the highway was

based upon. an All Points Bulletin founded upon pro- °

_ bable. cause: ‘and legal.in all ‘respects.

In regard to the subsequent .search warrant.

which: was issued in. Petitioners’. case,’ Respondent.

‘feels that SE, too, _was foundéd upon probable cause.

it is:Respondent' § contention that: the police. would

have been. justified, because they had probable cause,

in making a warrantless search -of the Petitioners’

automobile at the time of arrest. -Chambers v. Mar-

-, oney, 399 U.S. 423.26 LvEd.2d 419, 90 S.Ct: "1975 (1970).

i ieee Respondent" ‘s further gontention that by obtain-

ing a subsequent | search warrant from Judge Henderson,

the officérs adhered to and provided every possible

= constitutional. aera available to the Petitioners.

+. The information contained in the Affidavit a

deposition of facts Was” sufficient to support an Kn-

: dependent juasGtat assessment of probable cause.. In

addition,’ however, the Judge was ‘informed of the |

nature and source: ‘of this communique.

A side aa =

Pd

- Respondent lastly contends that in accord

ance with the abeision of the Honorable Supreme Court

of: the State of Idaho, since, the APB Paovaed pro=

bable- cause for the warrantless arrest updh the hig!

-way; there was. ‘also prstebie Cause for the issuance

of. the subsequent search warrant. _ Respondent ‘i's aware.

that the Whiteley Case, ‘ supra, speaks: to, the inde-

pendent judicial assessment of ‘probable cause and

issuance ofa warrant of arrest. prior to the init

-ation of an All Points ‘Bulletin. -Respohdent is al¥

ae j ; > cesar

‘aware that in the Petitioners’ case no such* judic

i se aes | |

assessment had been made: or warrant of arrest issutd

*

prior to the ‘iWitiation of thegAPB. "However, the

Respondent contends that though this information was

. not ‘communicated to a magistrate prior to fe |

ance of the APB, the information pie ie

"did give rjse- to probable cause and that this prob,

able cause sustained throughout: the facts: of this

case the legality ofthe police conduct .

__. WHEREFORE, Respondent” STATE OF IDAHO re.

spect fully prays that the Petition for Writ of Certs.

orari before this Honorable Court be denied. -”

| Of th % tae

DATED This. a = day of March; -3972

ed

% EN =

Respondent contended that the arrest of Petitioners

was a legal arrest and justified apart from the sub-

sequent arrest warrant. Respondent's contention

remains the same before this Honorabie Court ; that

_is to say, regardless of any defectiveness in the

—

arrest warrant, the initial confrontation between

the police and the Petitioners upon the highway was

based upon an All Points Bulletin founded upon pro-

bable cause and legal in all ‘respects.

In regard to the subsequent senteh: warrant

which was issued in Petitioners’ case, Respondent

feels that it,.too, was founded upon ‘probable cause.

It is Respondent's contention that the police would

have been. justified, - because ‘they had probable cause,

in _making a warrant less, search of the Petitioners’ .

automobile at the time of arrest. Chambers v. Mar-_

oney, 399 U.S. 42, 26 L.Ed.2d 419, 90 S.Ct. 1975 (1970).

It -is Respondent's further contention that by obtain-

ing a subsequent search warrant from Judge Henderson,

the officers adhered to and provided every possible

constitutional safeguard available to the Petitioners.

The information.contained in the Affidavit aa*

pnd of facts was sufficient to support an in-

addition, however, the Judge was informed of the

dependent judicial assessment of probable cause. In

nature and source of: this communique. ‘

a 30 =

bial Respondent fastly contends that in accord-

ance with the decision of the Honorable Supreme Court

of the State of Idaho, since the APB provided pro-

bable cause for the. warrantless arrest, upon the. high-

way, there was also probable.cause for the issuance

of the subsequent search warrant. . Respondent. is aware

that the Whiteley case, supra, speaks to the inde-

pendent judicial assessment of probable. cause and ~

issuance of a warrant of arrest prior to the initi-

-ation of an All Points Bulletin. _ Respondent is also

aware that in the Petitioners' case no such judicial

, assessment had been made ‘or warrant of arrest issued

prior to the initiation of the APB. However, the

Respondent contends that though this information was

not communicated to a magistrate prior to the issu-

-ance of the APB, the information ‘supporting the APB

did give rise to probable cause and that this prob-

able cause sustained throughoyt the facts of this

Case the legality of the police conduct.

-WHEREFORE, Respondent STATE-OF IDAHO re-

_ spectfully prays that the Petition for Writ of Certi-

orari before this Honorable Court be denied.

oe

“DATED This & S day of March, 1972..

eg Stes

Respectfully submitted,

~ 4 /

f a, fy . Pi (OR rd

Af Bs rs J f e

/ F i i ;

LY fit BF F <a

YY bad te Le s Ve , Ee

W. ANTHONY + BARK:

Attorney General

' State of Idaho

S:atehouse, Boise, Idaho 83707

ielephone: 208-384-2400

“ 7 : t.

I HEREBY CERTIFY That I have on this yA D any

of March, 1972, served-the foregoing BRIEF IN OPPOS-

ITION TO PETITION FOR WRIT OF CERTIORARI by placing

"true and correct copies thereof in the United States

| mail, postage prepaid; addressed to:

‘

Kidwell, McKee, Quane §& Harwood

Suite 434, Simplot Building

Boise, Idaho 83702

Attorneys for Petit?oners

Lary C. Walker

* Prosecuting Attorney

Washington County Courthouse

Weiser, Idaho | 83672.

- W. ANTHONY PARK

Attorney General.

State of Idaho

: a :

_ CERTIFICATE OF SERVICE. cat eens

sc aaaeatainnaanai

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