Ornelas v. United States
United States Supreme Court
517 U.S. 690, 116 S.Ct. 1657, 134 L.Ed.2d 911 (1996)
- Written by Rose VanHofwegen, JD
Facts
Police arrested Miguel and Ismael Ornelas (defendants) after searching Miguel’s car without a warrant and finding two kilograms of cocaine. Ornelas filed a motion to suppress the evidence on the ground that the police lacked probable cause. After a hearing, the magistrate judge concluded that police had reasonable suspicion but not probable cause for the search. However, the magistrate recommended denying suppression because the police had a drug-sniffing dog present, which would have inevitably found the drugs anyway. The trial judge decided that police had probable cause for the search once an officer discovered the loose panel where the drugs were hidden. Therefore, the judge admitted the evidence. On appeal, the Seventh Circuit applied a clear-error standard of review that defers to the trial court’s findings as to reasonable suspicion and probable cause. Noting a split among circuit courts as to whether a clear-error or de novo standard applies, the Supreme Court granted review.
Rule of Law
Issue
Holding and Reasoning (Rehnquist, J.)
Dissent (Scalia, J.)
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