Adams v. Williams

The Court's decision gave officers significantly increased powers in pursuing investigations and frisking suspects for weapons. It extended the circumstances in which police officers may stop and frisk a person for weapons. More importantly, the Court's decision was the first step in a series of cases expanding the situations in which a police officer may conduct a search of a person without first obtaining a search warrant.

In the 1968 case Terry v. Ohio, the Supreme Court held that a police officer may "stop and frisk" a person whom the officer has a reasonable suspicion to believe is carrying a weapon. This reasonable suspicion standard is a less rigorous standard than the "probable cause" requirement ordinarily required to support a search under the Fourth Amendment. In Adams, the Court considered the scope of its holding in Terry.

Early in the morning, while patrolling a high crime area in Bridgeport, Connecticut, police officer John Connolly was approached by an informant he knew and was told that Williams, who was sitting in a parked car nearby, was carrying narcotics. The informant also told officer Connolly that Williams had a gun tucked into his waistband. Connolly approached the car, knocked on the window, and asked Williams to open the car door. When Williams rolled down the window, the officer reached in and removed the gun from Williams' waistband, which was exactly where the informant had indicated. Based on his seizure of the handgun, the officer arrested Williams for unlawful possession of a pistol. As part of the arrest, Williams' car was also searched, and the police discovered heroin and additional weapons.

Williams was tried and convicted of charges of possessing both a handgun and narcotics in the state court, and his convictions were affirmed by the state appellate courts. Williams then filed a petition for a writ of habeas corpus in the U.S. District Court for the District of Connecticut. Habeas corpus, a Latin phrase meaning literally "you have the body," is a procedure in which a state prisoner asks a federal court to order his release from a state prison because his imprisonment in some way violates the U.S. Constitution. Williams claimed that the officer's reaching into his car and grabbing his gun was unreasonable, and thus violated the Fourth Amendment. Thus, he argued, the subsequent search of his vehicle which was based on the officer finding the gun was also illegal, and the evidence seized in the search should have been suppressed. The district court denied the writ of habeas corpus. However, the U.S. Court of Appeals for the Second Circuit reversed the district court and granted the writ of habeas corpus. The state then sought to appeal the case to the Supreme Court by petitioner for a writ of certiorari, which the Court granted.