Hill v. California

Two men who confessed to an armed robbery claimed that Hill (defendant) committed the robbery with them and that guns used in the robbery and stolen property were at Hill’s apartment. They provided a physical description of Hill and his address. When four officers went to Hill’s apartment, a different man, Miller, answered the door. Miller matched the physical description of Hill. The officers immediately arrested Miller for robbery. Although Miller showed police identification with his name, police continued to believe that Miller was Hill. Miller claimed that he was waiting for Hill and that he knew nothing about guns or stolen property. However, a pistol and ammunition were in plain sight in the room where police arrested Miller. The police searched Hill’s apartment incident to Miller’s arrest and seized evidence of the robbery. Hill later moved to suppress the evidence found in his apartment. Hill conceded that police had probable cause to arrest him but argued that police did not have probable cause to arrest Miller, and it was unreasonable to ignore Miller’s identification, so the search of Hill’s apartment incident to Miller’s arrest was unlawful. The California courts found that the evidence was lawfully admitted, because the officers had a reasonable, good-faith belief that Miller was Hill, and they had probable cause to arrest Hill, so the mistaken arrest of Miller was nonetheless valid.