Virginia v. Moore, 553 U.S. 164 (2008)
Primary Holding
A police officer does not violate the Fourth Amendment by making an arrest based on probable cause, even if the arrest is prohibited by state law.
In the case of Virginia v. Moore, the Supreme Court decided that police can make an arrest if they have a good reason to believe someone has committed a crime, even if state law says they shouldn't have arrested that person. This matters because it means that if police act on what they think is right, their actions won't be thrown out just because they didn't follow state rules. For consumers, this case highlights that while you have rights against unreasonable searches and arrests, those rights might not always protect you if the police have a strong reason to believe you're breaking the law. This case is relevant if you find yourself in a situation where you're arrested, and you believe the police didn't follow proper procedures according to state law.
AI-generated plain-language summary to help you understand this case
On February 20, 2003, David Lee Moore was stopped by two police officers in Portsmouth, Virginia, after they received a police radio report indicating that a person known as “Chubs” was driving with a suspended license. One of the officers recognized Moore by that nickname and confirmed that his license was indeed suspended. The officers arrested Moore for driving on a suspended license, a misdemeanor under Virginia law that carries a potential penalty of up to one year in jail and a $2,500 fine. During the arrest, the officers searched Moore and discovered 16 grams of crack cocaine and $516 in cash. The procedural history of the case began when Moore was charged with possession of cocaine with the intent to distribute. He filed a pretrial motion to suppress the evidence obtained during the search incident to his arrest, arguing that the arrest violated the Fourth Amendment. The trial court denied his motion, and Moore was subsequently found guilty and sentenced to five years in prison, with part of the sentence suspended. However, a panel of Virginia's intermediate appellate court reversed the conviction on Fourth Amendment grounds, stating that the officers should have issued a summons instead of making an arrest. This decision was later reinstated by the intermediate court sitting en banc but was ultimately reversed by the Virginia Supreme Court, which held that the arrest and subsequent search violated the Fourth Amendment because the officers lacked the authority to arrest Moore under state law. The case reached the Supreme Court of the United States on a writ of certiorari, where the central issue was whether a police officer violates the Fourth Amendment by making an arrest based on probable cause that is nonetheless prohibited by state law. The Supreme Court's decision would address the tension between state law enforcement practices and constitutional protections against unreasonable searches and seizures.
Whether a police officer violates the Fourth Amendment by making an arrest based on probable cause but prohibited by state law.
The judgment is reversed.
- Court
- Supreme Court
- Decision Date
- January 14, 2008
- Jurisdiction
- federal
- Case Type
- landmark
- Majority Author
- Scalia
- Damages Awarded
- N/A
- Data Quality
- high
Moore v. United States, 555 U.S. 1 (2008)
Consumer WonA district court must recognize its discretion to consider the disparity between the sentencing guidelines for crack and powder cocaine offenses when determining a sentence, as established by the Supreme Court's decision in Kimbrough v. United States.
Brendlin v. California, 551 U.S. 249 (2007)
Consumer WonA passenger in a vehicle is seized within the meaning of the Fourth Amendment when a police officer makes a traffic stop, and therefore has the standing to challenge the constitutionality of the stop.
Illinois v. Caballes, 543 U.S. 405 (2005)
Consumer LostThe use of a drug-detection dog to sniff a vehicle during a lawful traffic stop does not violate the Fourth Amendment, provided that the stop is not unreasonably prolonged beyond the time necessary to complete the mission of issuing a warning ticket.
Samson v. California, 547 U.S. 843 (2006)
Consumer LostA suspicionless search of a parolee conducted under California law does not violate the Fourth Amendment, as the conditions of parole significantly diminish the parolee's reasonable expectation of privacy.