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Adams v. Williams

Protective Searches For Weapons Are Permissible

On appeal, the Supreme Court reversed the court of appeals, concluding that the police officer's search of Williams was a reasonable protective search under its decision in Terry v. Ohio. As the Court explained, Terry held that a police officer may stop a person to investigate if the officer has a reasonable suspicion to believe that the person is committing a crime. The Fourth Amendment, which protects people against unreasonable searches and seizures, generally requires that a police officer have probable cause to believe that a search will recover evidence of a crime or contraband. However, in Terry the Court reasoned that a police officer should be able to protect himself from attack by a hostile suspect he has stopped to investigate. Thus, the officer is permitted to conduct a limited search of the suspect for weapons if he has a reasonable suspicion (which is less than probable cause) to believe that the suspect is armed.

Applying the Terry rule to the facts of the case, the Court concluded that the police officer had reasonable suspicion to believe that Williams was armed and dangerous, and thus he was justified in reaching into the car to seize the gun. The Court reasoned that the tip by the informant that Williams was carrying a gun in his waistband, the fact that Williams was suspected of carrying narcotics and a concealed weapon, and the fact that Williams was sitting alone in a parked car in the early morning in a high crime area all gave the officer "ample reason to fear for his safety." Further, this reasonable fear was increased when Williams failed to comply with the officer's request to get out of his car, but rather rolled down the window. Thus, the Court concluded: "Under these circumstances the policeman's action in reaching to a spot where the gun was thought to be hidden constituted a limited intrusion designed to insure his safety, and we conclude it was reasonable."

Having found the limited search for the weapon in Williams' waistband to be reasonable, the Court concluded that he was properly arrested for unlawful possession of the weapon. At this point, the police were justified in searching the remainder of the vehicle, because under the Fourth Amendment, as interpreted by the Supreme Court, the police may search a person and his automobile incident to a lawful arrest. Thus, the Court concluded that the evidence was properly admitted in Williams' trial, and that he was therefore not entitled to a writ of habeas corpus from the federal courts.

Additional topics

Law Library - American Law and Legal InformationNotable Trials and Court Cases - 1963 to 1972Adams v. Williams - Significance, Protective Searches For Weapons Are Permissible, A Dangerous Extension Of Terry, Impact