Brown Vs Texas 1979 Case Study
Brown v. Texas, 443 U.S. 47 (1979)Brief
Petitioner: Brown Respondent: Texas
FACTS
Two police officers, while cruising near noon in a patrol car, observed appellant and another man walking away from one another in an alley in an area with a high incidence of drug traffic. They stopped and asked appellant to identify himself and explain what he was doing.
One officer testified that he stopped appellant because the situation "looked suspicious, and we had never seen that subject in that area before."
The officers did not claim to suspect appellant of any specific misconduct, nor did they have any reason to believe that he was armed.
When appellant refused to identify himself, he was arrested for violation of a Texas
statute which makes it a criminal act for a person to refuse to give his name and address to an officer "who has lawfully stopped him and requested the information."
District Court and Appeals Court convicted; Supreme Court reversed
ISSUE
Were petitioners 4th Amendment rights violated when officers w/o reasonable suspicion stopped and questioned petitioner?
HOLDING
Yes, petitioners 4th Amendment rights were violated b/c the officers did not have sufficient reasonable suspicion to detain petitioner. The officers stated that b/c they never saw them in the area they considered that suspicious and sufficient justification to stop and investigate. This stop was unconstitutional and the officers had no right to detain or arrest petitioner.
"Whenever a police officer accosts an individual and restrains his freedom to walk away, he has seized' that person," and the Fourth Amendment requires that the seizure be "reasonable."
RATIONALE
The flaw in the State's case is that none of the circumstances preceding the officers' detention of appellant justified a reasonable suspicion that he was involved in criminal conduct. Officer Venegas testified at appellant's trial that the situation in the alley "looked suspicious," but he was unable to point to any facts supporting that conclusion.
In the absence of any basis for suspecting appellant of misconduct, the balance between the public interest and appellant's right to personal security and privacy tilts in favor of freedom from police interference.
The application of the Texas statute to detain appellant and require him to identify himself violated the Fourth Amendment because the officers lacked any reasonable suspicion to believe that appellant was engaged or had engaged in criminal conduct.
Petitioner: Brown Respondent: Texas
FACTS
Two police officers, while cruising near noon in a patrol car, observed appellant and another man walking away from one another in an alley in an area with a high incidence of drug traffic. They stopped and asked appellant to identify himself and explain what he was doing.
One officer testified that he stopped appellant because the situation "looked suspicious, and we had never seen that subject in that area before."
The officers did not claim to suspect appellant of any specific misconduct, nor did they have any reason to believe that he was armed.
When appellant refused to identify himself, he was arrested for violation of a Texas
statute which makes it a criminal act for a person to refuse to give his name and address to an officer "who has lawfully stopped him and requested the information."
District Court and Appeals Court convicted; Supreme Court reversed
ISSUE
Were petitioners 4th Amendment rights violated when officers w/o reasonable suspicion stopped and questioned petitioner?
HOLDING
Yes, petitioners 4th Amendment rights were violated b/c the officers did not have sufficient reasonable suspicion to detain petitioner. The officers stated that b/c they never saw them in the area they considered that suspicious and sufficient justification to stop and investigate. This stop was unconstitutional and the officers had no right to detain or arrest petitioner.
"Whenever a police officer accosts an individual and restrains his freedom to walk away, he has seized' that person," and the Fourth Amendment requires that the seizure be "reasonable."
RATIONALE
The flaw in the State's case is that none of the circumstances preceding the officers' detention of appellant justified a reasonable suspicion that he was involved in criminal conduct. Officer Venegas testified at appellant's trial that the situation in the alley "looked suspicious," but he was unable to point to any facts supporting that conclusion.
In the absence of any basis for suspecting appellant of misconduct, the balance between the public interest and appellant's right to personal security and privacy tilts in favor of freedom from police interference.
The application of the Texas statute to detain appellant and require him to identify himself violated the Fourth Amendment because the officers lacked any reasonable suspicion to believe that appellant was engaged or had engaged in criminal conduct.