Case Title: California v. Hodari D. 499 U.S. 621 or 111 S. Ct. 1547 (1991)
Prior History:
Patrol officers arrested the defendant in a high-crime area of Oakland.
Trial Court- Motion to discard evidence because the defendant was unlawfully seized.
The defendant pleaded that common law was not applied during his arrest.
The Juvenile court dismissed the motion and concluded that the evidence was admissible.
The defendant appealed.
The California Supreme Court reversed the Juvenile Court ruling.
Facts:
Police officers who were in patrol realized that four youths got panicked when they saw a police car.
The defendant and his companion ran in different directions.
The defendant, who ran on foot, was chased by one police officer.
The defendant did not see the police officer until the officer was almost upon him.
The defendant tossed a small rock of cocaine.
The police officer handcuffed the defendant.
Issue:
Is a suspect who is not under the physical control of the police officer seized when the officer is pursuing the suspect through a chase?
Does the fourth amendment allow a suspect to legally discard a piece of evidence by asserting that he dropped the evidence out of fear of unlawful seizure?
Holding:
Under the fourth amendment, a suspect is seized only if the police officer applies physical force on him. In the case of California v. Hodari, at the time the respondent tossed the rock of cocaine, there was no physical force that had been applied to him.
Reasoning:
The State Court of Appeal reversed the Juvenile Court ruling by claiming that the respondent was unlawfully seized. The court argued that the police officer had no reasonable suspicion to chase after the respondent and stop him, hence the respondent was under unlawful seizure at the time he dropped the rock of cocaine. The court suppressed the evidence because of the illegal seizure.
Decision:
Reversed and remanded