Atwater v. City of Lago Vista
532 U.S. 318, 121 S. Ct. 1536, 149 L. Ed.2d 549 (2001)

  • Atwater was driving around without a seatbelt (her kids weren't wearing them either). A policeman noticed this and pulled her over.
    • Under Texas law, driving without a seatbelt is a misdemeanor and has a maximum $50 fine (no possibility of jail time).
  • A verbal altercation ensued, and the policeman yelled at Atwater for being a bad mother, and then arrested her.
  • Atwater sued the city, claiming that her arrest for a misdemeanor was a violation of her 4th Amendment rights because it was an unreasonable seizure of her person.
    • The Civil Rights Act of 1871 (42 U.S.C. 1983) allows individuals to sue State and local government for civil rights violations.
  • The Trial Court found for Lago Vista. Atwater appealed.
    • The Trial Court found that she had violated the seat belt law, therefore the arrest was reasonable.
  • The Appellate Court reversed and found for Atwater.
    • The Appellate Court found that arresting someone for a misdemeanor was unreasonable.
  • The Appellate Court en banc reversed again and found for Lago Vista.
  • The US Supreme Court affirmed.
    • The US Supreme Court looked to the common law and found that historically, the police can arrest someone for any crime committed within their presence, even if it is only a misdemeanor.
      • However, there are counter-examples in the case law.
    • Atwater unsuccessfully argued that there should be a balancing test to determine whether the arrest was reasonable, but the Court found that the police were authorized (though not required) to make a custodial arrest without balancing costs and benefits or determining whether Atwater's arrest was necessary.
    • Atwater unsuccessfully argued that the police should not be able to arrest someone for crimes that do not carry a jail sentence, but the Court found that it would be unreasonable to expect the police to know what crime the person will eventually be charged with. They are not district attorneys and do not press charges.
  • In a dissent it was argued that an arrest for a fine-only misdemeanor was not reasonable because sending someone to jail for up to 48 hours (the time necessary to get him or her before a magistrate to be released) was too great an intrusion upon the personal liberty interests of one who had committed such a relatively minor offense as would merit only a fine as punishment.
    • In addition, the dissent worried that allowing the arresting officer sole discretion to determine if the arrest was 'reasonable' put too much power in their hands and carried the potential for abuse.
  • Basically, in this case the Court refused to draw any bright line rules and said that it is up to the police officer at the time to determine the best course of action based on the specific facts on the ground. To limit the police's abilities with bright line rules would make it difficult for them to do their jobs and could result in dangerous situations.
    • The Court agreed that in this particular case, the policeman was being a jerk, but they didn't want to set a precedent based on this one instance.
      • The court noted that cases like this are very unusual and it takes a lot of effort to file an arrest report, so it was unlikely to be abused.
  • Btw, because a search incident to a lawful arrest (SILA) is allowed whenever someone is arrested, this ruling gave the police significantly enhanced search powers.