Hayes v. Florida

Background

A man named Hayes was questioned after a series of burglary-rapes in Punta Gorda, Florida. Police found latent fingerprints and a herringbone shoe print at a crime scene. After interviewing 30 to 40 men, officers treated Hayes as a principal suspect, went to his home, and told him he would be arrested if he did not go voluntarily; Hayes chose to accompany them. Officers seized shoes in plain view, took him to the station, fingerprinted him, and later arrested him when the prints matched. Hayes moved to suppress the prints as the product of an illegal detention; state courts upheld the conviction and the Supreme Court reviewed the case.

Reasoning

The Court asked whether police may remove someone from his home to a station for fingerprinting without consent, a warrant, or probable cause. Relying on Davis v. Mississippi and Dunaway v. New York, the Court held that involuntary transport from a private dwelling to a police station is like an arrest and requires probable cause or judicial authorization. The opinion distinguished short field stops, which can rest on reasonable suspicion, and left open narrowly limited or court-authorized procedures that were not presented here.

Real world impact

The ruling prevents police from taking people from their homes to the station for fingerprints unless officers have probable cause, a warrant, or specific judicial authorization. Evidence obtained after such removals can be suppressed. States may consider judicial procedures for fingerprinting, but courts differ on those methods.

Dissents or concurrances

Justice Brennan, joined by Justice Marshall, agreed the conviction should be reversed but criticized the Court’s broader discussion of on-site fingerprinting as unnecessary.