## Facts

- Texas law made certain seatbelt violations misdemeanors punishable only by a $25–$50 fine and authorized warrantless arrest by an officer who observed the violation.
- In March 1997, Gail Atwater drove in Lago Vista, Texas with her young children in the front seat; none wore seatbelts.
- Officer Bart Turek stopped Atwater after observing the seatbelt violations; Atwater lacked license and insurance documents and said her purse had been stolen the day before.
- Atwater asked to take her distressed children to a nearby friend’s house; the officer refused until a friend arrived to take the children.
- The officer handcuffed Atwater, transported her to the police station, and processed her through booking (including removal of personal items, photographing, and placement in a cell for about an hour).
- Atwater appeared before a magistrate and was released on bond.
- She ultimately pleaded no contest and paid a $50 fine.
- Atwater sued under 42 U.S.C. § 1983, alleging an unreasonable seizure in violation of the Fourth Amendment.
- The district court entered summary judgment for the defendants, and the Fifth Circuit (en banc) affirmed, relying on the existence of probable cause and the absence of an unusually harmful arrest method.

## Issues

1. Whether the Fourth Amendment prohibits a warrantless custodial arrest for a minor misdemeanor committed in an officer’s presence when the offense is punishable only by a fine.
2. Whether asserted common-law limits on misdemeanor arrests require a constitutional rule barring custodial arrest for fine-only offenses despite probable cause.

## Decision

- The Supreme Court affirmed in a 5–4 decision.
- The Court held that when an officer has probable cause to believe a person committed even a very minor criminal offense in the officer’s presence, the officer may make a custodial arrest without violating the Fourth Amendment.
- The Court declined to adopt a categorical rule forbidding custodial arrests for fine-only offenses, citing unclear historical support and significant administrability problems.
- The Court acknowledged the indignity of Atwater’s treatment but concluded that probable cause supplied the governing constitutional standard for the arrest’s reasonableness.

## Legal Principles

- A warrantless custodial arrest for a misdemeanor committed in an officer’s presence is generally reasonable under the Fourth Amendment when supported by probable cause.
- The Fourth Amendment does not require a “fine-only offense” limitation on arrest authority as a matter of federal constitutional law.
- Courts generally do not apply case-by-case balancing to determine whether a custodial arrest is reasonable when probable cause exists for an observed criminal offense.
- Policy limits on arrest authority for minor offenses may be imposed by state or local law, but they are not compelled by the Fourth Amendment.

## Conclusion

The Court held that the Fourth Amendment permits a warrantless custodial arrest based on probable cause for any misdemeanor committed in an officer’s presence, even when the offense is punishable only by a fine, rejecting a constitutional rule that would restrict custodial arrests for minor offenses.


Atwater v. City of Lago Vista, 532 U.S. 318 (2001)