County of Riverside v. McLaughlin

County of Riverside v. McLaughlin

Argued January 17, 1991
Decided May 13, 1991
Full case name County of Riverside and Cois Byrd, Sheriff of Riverside County, Petitioners v. Donald Lee McLaughlin, et al.
Citations

500 U.S. 44 (more)

111 S. Ct. 1661; 114 L. Ed. 2d 49; 1991 U.S. LEXIS 2528; 59 U.S.L.W. 4413; 91 Cal. Daily Op. Service 3503; 91 Daily Journal DAR 5506
Prior history Certiorari to the United States Court of Appeals for the Ninth Circuit
Argument Oral argument
Opinion Announcement Opinion announcement
Holding
An individual (or individuals) arrested without a warrant must know the probable cause for their arrest from law enforcement officials within 48 hours.
Court membership
Chief Justice
William Rehnquist
Case opinions
Majority O'Connor, joined by Rehnquist, White, Kennedy, Souter
Dissent Marshall, joined by Blackmun, Stevens
Dissent Scalia

County of Riverside v. McLaughin, 500 U.S. 44 (1991), was a United States Supreme Court case which involved the question of whether suspects arrested without a warrant (warrantless arrests) must be brought into court within a reasonable amount of time to determine if there is probable cause for holding the suspect in custody.

Overview

The County of Riverside v. McLaughlin (1991) case was a court case dealing with the interpretation of the Fourth Amendment of the United States Constitution in a probable cause case involving a warrantless arrest. In this instance, the Fourth Amendment is used by the plaintiff(s) to argue that the clause “warrants must be legally justified with probable cause” also applies to warrantless arrests because it was implied that it would be unreasonable, if not unconstitutional, for someone to be arrested without determining probable cause. This U.S. Supreme Court also used previous precedent derived from previous Supreme Court cases – such as the Gerstein v. Pugh (1975) case – to arrive at their final decision.[1]

This lawsuit was filed in 1987 by the plaintiff – Donald Lee McLaughlin – against the County of Riverside (California). He asked the United States District Court (Central District of California) to issue an injunction ordering that the County stop its policies on warrantless arrests, arguing that the practice may be unconstitutional.[2] Eventually, the County of Riverside appealed the case to the Ninth Court of Appeals after the District Court sided with the plaintiff; the Court of Appeals also agreed with the plaintiff’s arguments. This case then went before the U.S. Supreme Court. In a 5-4 vote, the Supreme Court justices found that the County of Riverside’s practices in regards to warrantless arrests were unconstitutional and ruled that suspects who are arrested without a warrant must be given probable cause within 48 hours.[3]

Background

In 1987, the plaintiff – Donald Lee McLaughlin – filed a complaint in the United States District Court (Central District of California) against Riverside County. In it, the complaint alleged that he was jailed in the Riverside County Jail without prosecutors (or any law enforcement officials) explaining to him the reasons why he was held (probable cause). McLaughlin requested an order from the judge that would require that defendants and the County provide those who were arrested without warrants probable cause in a reasonable amount of time.[2]

Riverside County responded to this lawsuit by saying that McLaughlin had no legal standing to bring suit against the County because – based on Los Angeles v Lyons (1983) he failed to show that he was going to be subject to unconstitutional actions by the County, such as detention without probable cause.[2] The County requested that the suit be dismissed. During this time, a second amended complaint was accepted (as individuals and class representatives), which added three more plaintiffs –Johnny E. James, Diana Ray Simon, and Michael Scott Hyde – who alleged that law enforcement officials arrested them without a warrant and were held without probable cause.

In 1989, the plaintiffs requested the District Court judge issue an injunction ordering the County of Riverside to give probable cause to those who were detained in a reasonable amount of time. The judge granted the request based on the precedent that the County’s practice violated the U.S. Supreme Court decision in the Gerstein case. Riverside County then appealed the case to the U.S Court of Appeals of Ninth Circuit; the Appeals Court combined the McLaughlin case together with McGregor v. County of San Bernardino (due to the similarities between the cases), and upheld the injunction on the basis that the County was violating precedent set by the Gerstein case. The Appeals Court noted that the detainees were “in custody and suffering injury as a result of the defendants' allegedly unconstitutional action”.[2] This case then went to the U.S. Supreme Court for review.

Opinion of the court

In a split 5-4 vote, the U.S. Supreme Court ruled that suspects who are arrested without a warrant must be provided probable cause within 48 hours of their arrest. Using the precedent set by the Gerstein case – in which the Supreme Court ruled that Florida’s practice of keeping suspects for 30 days without probable cause was unconstitutional[3] – and close interpretation of the Fourth Amendment, they found that the County of Riverside’s practice of keeping suspects in custody without probable cause determination amounted to illegal detention (or held in custody without being charged). Illegal detention would unquestionably violate the unreasonable search and seizure clause of the Fourth Amendment; withholding probable cause determination to suspects would also violate the Fourth Amendment as well.

Summary of the Majority Opinion

Justice Sandra Day O’Connor wrote the opinion for the majority. The key ruling within the majority opinion is seen here:

"This is not to say that the probable cause determination in a particular case passes constitutional muster simply because it is provided within 48 hours. Such a hearing may nonetheless violate Gerstein if the arrested individual can prove that his or her probable cause determination was delayed unreasonably. Examples of unreasonable delay are delays for the purpose of gathering additional evidence to justify the arrest, a delay motivated by ill will against the arrested individual, or delay for delay's sake. In evaluating whether the delay in a particular case is unreasonable, however, courts must allow a substantial degree of flexibility. Courts cannot ignore the often unavoidable delays in transporting arrested persons from one facility to another, handling late-night bookings where no magistrate is readily available, obtaining the presence of an arresting officer who may be busy processing other suspects or securing the premises of an arrest, and other practical realities.
Where an arrested individual does not receive a probable cause determination within 48 hours, the calculus changes. In such a case, the arrested individual does not bear the burden of proving an unreasonable delay. Rather, the burden shifts to the government to demonstrate the existence of a bona fide emergency or other extraordinary circumstance. The fact that in a particular case it may take longer than 48 hours to consolidate pretrial proceedings does not qualify as an extraordinary circumstance. Nor, for that matter, do intervening weekends. A jurisdiction that chooses to offer combined proceedings must do so as soon as is reasonably feasible, but in no event later than 48 hours after arrest"[3]

Justice O’Connor – as well as the rest of the majority – rejected the County of Riverside’s claims that “allege personal injury fairly traceable to the defendant's allegedly unlawful conduct and likely to be redressed by the requested relief.”;[3] they argued the plaintiffs who were arrested and held without probable cause determination were suffering direct injury (emotional) because they were not given the reasons for their arrest. The ruling stated that any suspects that are arrested without a warrant by law enforcement have to know why they are being arrested (determination of probable cause) – either from a law enforcement officer or a judge – within 48 hours, regardless of any circumstances.

Chief Justice Rehinquist, Justice White, Justice Kennedy, and Justice Souter joined Justice O’Connor in the majority.[3]

Dissenting Opinion

In County of Riverside v McLaughlin, there were two separate dissent opinions written: one by Justice Scalia[4] and one written by Justice Marshall, joined by Justice Blackmun and Justice Stevens.[5]

Justice Marshall wrote this short dissenting opinion, and he is joined by Justice Blackmun and Justice Stevens. In this opinion, he states:

"In Gerstein v. Pugh, 420 U.S. 103 (1975), this Court held that an individual detained following a warrantless arrest is entitled to a "prompt" judicial determination of probable cause as a prerequisite to any further restraint on his liberty. See id., at 114-116, 125. I agree with Justice Scalia that a probable-cause hearing is sufficiently "prompt" under Gerstein only when provided immediately upon completion of the "administrative steps incident to arrest," id., at 114. See post, at 4-5. Because the Court of Appeals correctly held that the County of Riverside must provide probable cause hearings as soon as it completes the administrative steps incident to arrest, see 888 F. 2d 1276, 1278 (CA9 1989), I would affirm the judgment of the Court of Appeals. Accordingly, I dissent"[5]

Justice Marshall argued in the short dissent that the precedence from the Gernstein case was enough to determine the “prompt” deliverance of probable cause to suspects in warrantless arrests, and thought that the reasoning in this case was redundant. Hence he dissented.

Justice Scalia also dissented, yet he offered a more detailed perspective on his dissenting opinion. His opinion is stated below:

“Today, however, the Court discerns something quite different in Gerstein. It finds that the plain statements set forth above (not to mention the common-law tradition of liberty upon which they were based) were trumped by the implication of a later dictum in the case which, according to the Court, manifests a "recognition that the Fourth Amendment does not compel an immediate determination of probable cause upon completing the administrative steps incident to arrest." Ante, at 8 (emphasis added). Of course Gerstein did not say, nor do I contend, that an "immediate" determination is required. But what the Court today means by "not immediate" is that the delay can be attributable to something other than completing the administrative steps incident to arrest and arranging for the magistrate — namely, to the administrative convenience of combining the probable-cause determination with other state proceedings. The result, we learn later in the opinion, is that what Gerstein meant by "a brief period of detention to take the administrative steps incident to arrest" is two full days. I think it is clear that the case neither said nor meant any such thing….
…Of course even if the implication of the dictum in Gerstein were what the Court says, that would be poor reason for keeping a wrongfully arrested citizen in jail contrary to the clear dictates of the Fourth Amendment. What is most revealing of the frailty of today's opinion is that it relies upon nothing but that implication from a dictum, plus its own (quite irrefutable because entirely value laden) "balancing" of the competing demands of the individual and the State. With respect to the point at issue here, different times and different places — even highly liberal times and places — have struck that balance in different ways. Some Western democracies currently permit the Executive a period of detention without impartially adjudicated cause. In England, for example, the Prevention of Terrorism Act 1989, 14(4), 5, permits suspects to be held without presentation and without charge for seven days. 12 Halsbury's Stat. 1294 (4th ed. 1989). It was the purpose of the Fourth Amendment to put this matter beyond time, place and judicial predilection, incorporating the traditional common-law guarantees against unlawful arrest. The Court says not a word about these guarantees, and they are determinative. Gerstein's approval of a "brief period" of delay to accomplish "administrative steps incident to an arrest" is already a questionable extension of the traditional formulation, though it probably has little practical effect and can perhaps be justified on de minimis grounds. [n.2] To expand Gerstein, however, into an authorization for 48-hour detention related neither to the obtaining of a magistrate nor the administrative "completion" of the arrest seems to me utterly unjustified. Mr. McLaughlin was entitled to have a prompt impartial determination that there was reason to deprive him of his liberty — not according to a schedule that suits the State's convenience in piggybacking various proceedings, but as soon as his arrest was completed and the magistrate could be procured.”[4]

Justice Scalia argued that the Court thought the precedent established in the Gerstein case in regards to issues associated with warrantless arrests was more than enough in determining when probable cause is determined for suspects. He also argued that the court disregarded the guarantees the Fourth Amendment outlined in regards to holding people in custody. Finally, Justice Scalia argued that the Court’s further interpretation of the Gerstein case to mandate that law enforcement must determine probable cause in a set amount of time was completely unnecessary; he felt that it was completely unrelated to clearing arrest-related administrative affairs or assigning a judge to the suspect’s case. He also felt that the probable cause determination for suspects arrested without a warrant should be less strict. Or in other words, Scalia's argument can be interpreted as “probable cause determination will be taken care of when the needed institution – the justice system – is fully available to hear the suspect’s case”

Historical significance

This case is quite significant in a few ways. First, the question of "when does a neutral and detached magistrate have to give probable cause determination based on law enforcement's reasons to execute a suspect's warrantless arrest?" became more defined, in the form of a limited time period. By looking at the precedent case used to decide the outcome of the McLaughlin case – the Gerstein case – the interpretation of that case became much stricter.

Also, the meaning of the "unreasonable search and seizure" clause in the Fourth Amendment became strictly defined in that law enforcement must give a reason to seize the person(s) for detention within a pre-determined amount of time, or it would be considered “illegal detention” because no reason was given for the suspect’s arrest.

The basis of County of Riverside v. McLaughlin was used in a dissenting opinion in Powell v. Nevada in 1994.[6]

Notes

  1. ↑ "Riverside County v. McLaughlin". Oyez Project - IIT Chicago-Kent College of Law. Retrieved 3 November 2011.
  2. 1 2 3 4 "County of Riverside v. McLaughlin (89-1817), 500 U.S. 44 (1991)". Cornell University Law School. Retrieved 2 November 2011.
  3. 1 2 3 4 5 "Majority Opinion - County of Riverside v. McLaughlin (89-1817), 500 U.S. 44 (1991)". Cornell University Law School. Retrieved 3 November 2011.
  4. 1 2 "Justice Scalia's Dissent - http://www.law.cornell.edu/supct/html/89-1817.ZD2.html". Cornell University Law School. Retrieved 3 November 2011. External link in |title= (help)
  5. 1 2 "Justice Marshall's Dissent - County of Riverside v. McLaughlin (89-1817), 500 U.S. 44 (1991)". Cornell University Law School. Retrieved 3 November 2011.
  6. ↑ "Powell v. Nevada (92-8841), 511 U.S. 79 (1994)". Cornell University Law School. Retrieved 3 November 2011.
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