Rios v. United States

Background

A man was federally charged with receiving and hiding heroin after Los Angeles police in plain clothes followed him from a parking lot into a taxi, approached the cab, and a package of narcotics appeared on the taxi floor. The state trial judge found the search unlawful, suppressed the heroin, and entered an acquittal. Later a city officer brought the evidence to federal narcotics agents, which led to a federal indictment and a contested hearing about how the seizure occurred.

Reasoning

The Court focused on whether the heroin was taken in a way that would have violated the Constitution’s protection against unreasonable searches if federal officers had done it. The Court noted a companion decision holding that evidence taken unreasonably by state officers must be excluded in federal trials. Because the record contains conflicting stories about whether the officers had actually arrested or merely questioned the passenger before the package was found, the Court concluded the federal trial court must reevaluate the facts and decide when any arrest occurred and whether there was probable cause.

Real world impact

The decision sends the case back to the federal trial court to sort out the witnesses’ differing accounts and then determine whether the seized heroin can be used in the federal trial. It signals that federal courts cannot simply accept state seizures when the facts suggest no probable cause, and it requires specific factual findings before evidence taken by local police can be admitted in federal prosecutions.