Warren v. Mississippi

Background

Police officers driving to investigate a reported disturbance encountered a man a block or two from the scene who was splattered with blood and had a bloody hand. He said he had been in a nightclub fight and was going home. Officers placed him in their squad car and then discovered a brutal murder at the reported location. A detective arrived, arrested the man, took him to the station, and sent his clothes to a laboratory. He was later charged with murder and convicted after a trial judge allowed most of the lab evidence.

Reasoning

The lower courts disagreed about whether evidence gathered after the initial stop should be used at trial. The trial judge suppressed evidence gathered between the time the man was first put in the squad car and his formal arrest, but concluded there was probable cause once the murder was discovered and therefore allowed the clothes and lab results. The Supreme Court of Mississippi affirmed the conviction, treating the items as properly obtained during an investigative stop. The U.S. Supreme Court declined to review that state-court ruling when it denied certiorari.

Real world impact

Because the high court refused to take the case, the Mississippi decision allowing the clothing and lab evidence remains in place and the conviction stands. The denial is not a ruling on the constitutional question by the U.S. Supreme Court, so the legal issue about investigative detentions and when evidence may be used could still be revisited in other cases.

Dissents or concurrances

Three Justices dissented from the denial, arguing the state decision may conflict with a recent case (Dunaway v. New York) and urging the Court to vacate and remand for reconsideration.