California v. Hodari D.
Headline: Fleeing suspect ruling: Court held that a person who runs and does not submit to a police show of authority is not legally seized, allowing officers to keep items dropped while the person is fleeing.
Holding:
- Allows admission of items thrown away while a suspect flees
- Limits exclusionary rule use for unsuccessful police pursuits
- Clarifies seizure occurs only on submission or physical control
Summary
Background
Two plainclothes police officers in Oakland saw a group of youths and chased when some ran. One youth, Hodari D., ran away, tossed a small rock that turned out to be crack cocaine, and was tackled moments later. Hodari moved to suppress the discarded drugs; the California Court of Appeal said he had been seized when he saw an officer approaching and ordered to stop, and it suppressed the evidence. The State appealed to the Supreme Court.
Reasoning
The Court addressed one narrow question: was Hodari “seized” under the Constitution at the moment he dropped the drugs? The majority said no. It explained that a seizure of a person requires either physical control (touching or tackling) or submission to an officer’s authority. A police chase or shouted command that is not obeyed does not count as a seizure. The Court relied on the common-law meaning of seizure and prior cases discussed in the opinion, and it emphasized that the exclusionary rule should deter unlawful, successful seizures rather than failed attempts to stop fleeing suspects. The Court reversed the California Court of Appeal and sent the case back for further proceedings.
Real world impact
The ruling means items a person throws away while running from police can be treated as abandoned and admitted in court if the person had not yet been physically caught or had not submitted. The decision clarifies when a Fourth Amendment “seizure” of a person begins and limits suppression of evidence when a suspect keeps fleeing.
Dissents or concurrances
Justice Stevens (joined by Justice Marshall) dissented, warning this narrow rule departs from earlier rulings and could encourage aggressive police displays that evade constitutional protection.
Opinions in this case:
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