Case Summary: California V. Hodari D. 499 U.S. 621, 11S. Ct.1547 (1991)
Case Facts
The case involved two police officers who were in patrol in a car than was unmarked if they were policemen. The officers were in street clothes and only wore jackets with the writings “police” at the front and back of their jackets. The area where they were patrolling tended to report high crimes that the other sites. A small group of youths, including the accused, were gathered around a parked car near a checking point. When the kids saw the police officers, they panicked and started running away. One of the two police officers alighted the vehicle and ran around the block to catch the accused who had fled into the side street (Coble, 2019). The accused boy was running in the street looking behind to check the police officers and did not notice the police who had went for him from around the road. He suddenly saw the officer and panicked and tossed towards the officer whet looked like a small stone. Immediately after throwing the stone, the officer tackled the boy and handcuffed him behind his back. The rock that the accused had tossed to the officer was oater found out that it was not a stone but instead crack cocaine. The court denied the motion.
Legal Issues
The case’s legal issue was whether the seizure had occurred when the accused had dropped the drugs.
Holding of Majority
The ruling held that the seizure of the drugs had not occurred when the drugs were dropped. After further review, the highest Californian court reversed the holding of the court. The court stated that the accused had seized when he came into sudden contact with the police. According to the fourth amendment, a person is said to have been captured if, according to all the circumstances the person was in, he would believe that there was no way he was free leaving the place such as through a “show of authority” (Johnson & Stephens 2018). The test can conclude that an act was a show of authority is always an objective one. The test is not whether the person sees that the police are ordering him to restrict his movement, but whether the words the police officer utters or his actions show that the person is prohibited from moving.
Reasoning behind Holding
The court reversed the ruling, holding that the accused victim had been seized when he saw the police coming towards him. The seizure of cocaine that the police had done was unreasonable under the constitution’s fourth amendment. The cocaine obtained as evidence was not valid since it had been seized illegally (Johnson & Stephens 2018). The supreme court of California denied the application that the state had sent for review of the case.
Importance of the Case to the Criminal Justice System and American Society as a whole
Through the case, criminal justice knew the facts regarding the show of authority concerning force application. By physical force, a seizure did not occur when the accused had not fought back. In the defendant’s case, he did not involve any use of force, and he ha not been touched when he discarded the cocaine. The court decided that the test for a show of authority was objective, and the defendant was not seized of the cocaine until he was tackled.
References
Johnson, C. W., & Stephens, D. L. (2018). Survey of Washington Search and Seizure Law: 2019 Update. Seattle UL Rev., 42, i.
Coble, D. (2019). The Fourth Amendment: Annotated for the Federal District of S.C. The Fourth Amendment: Annotated for the Federal District of S.C., Everyday Evidence Books (2019).