Ornelas v. United States

The case established that an appeals court, when reviewing a trial court's conclusions on reasonable suspicions by police and the existence of probable cause for a warrantless police search, must thoroughly review the trial court's factual findings rather than accept them at face value.

In December of 1992, Michael Pautz, a detective with the Milwaukee County Sheriff's Department in Milwaukee, Wisconsin, was downtown, conducting surveillance for drug activity. In the early morning hours, Pautz spotted a 1981 two-door automobile with California license plates parked at a motel. Pautz felt suspicious because California is a "source state" for illegal drugs and because the automobile was of a kind favored by drug couriers for its many secret compartments. A check of the motel registry, the car's registration, and an inquiry to the Narcotics and Dangerous Drugs Information System revealed that the registered operators of the car, Saul Ornelas and Ismael Ornelas-Ledesma were considered by federal law enforcement officials to be known drug traffickers.

Accompanied by Merlin, a drug-sniffing dog, Milwaukee detectives waited outside the motel for the men to exit. When Ornelas and Ornelas-Ledesma approached the Oldsmobile to leave the motel, the detectives confronted them and asked if they had any illegal drugs in the car. Ornelas and Ornelas-Ledesma answered in the negative, so the detectives asked for permission to search. Ornelas and Ornelas-Ledesma consented, and a deputy performed the search. Some time into the search, the deputy noticed a rusty screw holding a door jam adjacent to a loose panel. The deputy removed the panel and found two kilograms of cocaine.

Ornelas and Ornelas-Ledesma were charged in federal court with trafficking in cocaine. Before trial, they moved the court to exclude the cocaine evidence, arguing that it was obtained in violation of their Fourth Amendment rights against unreasonable search and seizure. Ornelas and Ornelas-Ledesma pleaded guilty to the charges, but they reserved the right to challenge the decision to deny their motion. After a series of decisions and appeals between the magistrate judge, the district court, and the U.S. Court of Appeals for the Seventh Circuit ended in the federal government's favor, the men appealed to the U.S. Supreme Court.

The defendants argued that the appeals court committed an error warranting reversal when it conducted a deferential review of the facts in the case. In an 8-1 decision, the High Court agreed, and it vacated the holding of the appeals court and remanded the case. According to the majority, the appeals court should not have deferred to the factual findings of the trial court. Instead, it should have conducted a full, or de novo, review of the facts.

Chief Justice Rehnquist, writing for the majority, discussed the nature of Fourth Amendment claims of unreasonable search and seizure and concluded that it was not standard practice for appeals courts to defer to trial courts in reviewing the facts in such a case. Such a case usually requires a court to determine either: (1) whether a police officer who performed a limited patdown search for weapons without obtaining a warrant from a magistrate had reasonable suspicion to believe that criminal activity was afoot; or (2) whether a police officer who conducted a warrantless search of a person or place had probable cause to believe a crime has been committed. These questions are difficult questions for courts to answer because "[a]rticulating precisely what `reasonable suspicion' and `probable cause' mean is not possible." They are "fluid concepts that take their substantive content from the particular contexts in which the standards are being assessed."

In order to achieve a more meaningful jurisprudence on the questions, the majority felt it best to require that appeals courts conduct de novo review in cases where the questions arise. The Court cited three main reasons for its decision. First, to hold otherwise would subject Fourth Amendment jurisprudence to the whims of trial court judges. Second, the legal rules for the issues of reasonable suspicion and probable cause "acquire content only through application." If appeals courts are to clarify and control the legal principles that guide those issues, they must be able to give meaning to the principles by thoroughly considering all of the facts on record. Third, full review by appeals courts unifies precedent, makes law enforcement more predictable, and generally stabilizes the law.