## Facts

- A woman was raped in her home in Meridian, Mississippi, on December 2, 1965; her description of the assailant was limited to “a Negro youth.”
- Police recovered latent finger and palm prints from the window area believed to be the point of entry.
- Over about 10 days, Meridian police, without warrants, brought at least 24 Black youths to headquarters for brief questioning and fingerprinting, releasing them without charges; they also questioned dozens of others elsewhere.
- John Davis, a 14-year-old Black youth who had occasionally worked for the victim, was taken in on December 3, questioned, fingerprinted, and released; he was questioned multiple times between December 3 and 7 and shown to the victim several times without being identified.
- On December 12, police, concededly without a warrant or probable cause, transported Davis roughly 90 miles to Jackson, jailed him overnight, and the next day administered a lie-detector test and obtained a signed statement before providing counsel.
- Davis was returned to Meridian and jailed; on December 14, while confined, police took his fingerprints again and sent them (with prints from other youths) to the FBI for comparison with the latent prints.
- The FBI reported a match between Davis’s December 14 fingerprints and the latent prints; the State introduced the fingerprint match at trial over an objection that it resulted from an unlawful detention.

## Issues

1. Whether fingerprints obtained during an involuntary investigatory detention unsupported by a warrant or probable cause must be excluded as the product of an unconstitutional seizure under the Fourth and Fourteenth Amendments.
2. Whether fingerprint evidence is exempt from the exclusionary rule applicable to evidence obtained through unconstitutional searches and seizures.
3. Whether the Fourth Amendment constrains detentions undertaken solely to obtain fingerprints during the investigative stage.

## Decision

- The Supreme Court reversed the state-court judgment affirming Davis’s conviction and remanded.
- The Court held that fingerprint evidence is not exempt from the exclusionary rule and is inadmissible when obtained through unconstitutional seizures.
- The Court held that the Fourth Amendment governs involuntary detentions at the investigatory stage as well as at the accusatory stage.
- The Court held that detentions undertaken solely to obtain fingerprints are “seizures” subject to Fourth Amendment constraints.
- Because Davis’s fingerprints were obtained during an unlawful detention lacking a warrant or probable cause, they should have been excluded.

## Legal Principles

- The exclusionary rule applies in state prosecutions to all evidence obtained by searches or seizures that violate the Constitution, including fingerprints.
- Involuntary detention for investigative purposes is a Fourth Amendment seizure even if it occurs before formal arrest or charging.
- Detaining a person solely to obtain fingerprints must comply with Fourth Amendment standards; utility of fingerprinting does not justify dragnet-style seizures without individualized justification.
- The Court left open whether narrowly defined procedures could, in some circumstances, permit investigative fingerprinting of persons for whom there is no probable cause to arrest, but found no such procedures were attempted here.

## Conclusion

The Court ruled that fingerprints taken from a suspect during an investigatory detention concededly unsupported by a warrant or probable cause are the fruit of an unconstitutional seizure and must be excluded, reversing the conviction that relied on that fingerprint evidence.


Davis v. Mississippi, 394 U.S. 721 (1969)