Henry v. United States

Background

A man was convicted for possessing three cartons of radios stolen from an interstate shipment. FBI agents, investigating a separate interstate theft, watched him and a companion load cartons from a gangway in a residential alley, follow them, and later stop their car. The agents stopped the car, searched it, took the cartons and the men to the office, and only hours later learned the cartons contained stolen radios. A motion to suppress the evidence was denied and the conviction was affirmed below.

Reasoning

The central question was whether the agents had probable cause to arrest when they stopped the car. The Court explained that the Fourth Amendment requires probable cause — facts that would make a reasonable person believe a crime is being committed — and that mere suspicion, rumor, or vague tips are not enough. The Court found the agents’ information about the companion was undefined, their observation of ordinary actions (riding in a car, picking up packages in a residential alley) was not incriminating, and the later discovery of contraband cannot justify an earlier arrest. Because there was no probable cause at the time of the stop, the search and the evidence that followed could not support the conviction.

Real world impact

The decision reinforces that law enforcement cannot make warrantless arrests or searches based on thin suspicion or vague tips; agents need clearer, contemporaneous facts before stopping and searching. The ruling reverses this conviction and emphasizes protection of citizens’ privacy against easy arrests.

Dissents or concurrances

A dissent argued that the prolonged surveillance, the sighting of labeled cartons in the car, and untruthful answers gave agents sufficient grounds to stop, search, and arrest, and would have upheld the conviction.