Facts
- Detectives at Miami International Airport observed William Joseph Royer traveling under an assumed name with a one-way, cash-purchased ticket and checked luggage tagged in the same assumed name; they believed he fit a drug-courier profile.
- The detectives approached Royer in the concourse, identified themselves, and asked to speak with him; Royer agreed.
- Royer produced his airline ticket (assumed name) and driver’s license (true name); after questioning about the discrepancy, Royer appeared nervous.
- The detectives told Royer they suspected him of transporting narcotics, retained his ticket and license, and asked him to accompany them to a small room off the concourse; Royer went with them without being told he was free to leave.
- Without Royer’s consent, one detective retrieved Royer’s checked suitcases and brought them to the room.
- When asked to consent to a search, Royer handed over a key and unlocked one suitcase, which contained marijuana; he did not object when officers pried open a second suitcase, which also contained marijuana.
- Royer was formally arrested after the marijuana was discovered.
Issues
- Whether retaining Royer’s ticket and license and moving him to a small room for continued detention converted a permissible investigative stop into an unlawful de facto arrest lacking probable cause under the Fourth Amendment.
- Whether Royer’s apparent consent to search his luggage was voluntary or invalid as the product of an unlawful detention.
Decision
- The Supreme Court affirmed the suppression ruling.
- The Court held the detectives seized Royer for Fourth Amendment purposes when they identified themselves as narcotics agents, expressed suspicion, retained his ticket and license, and directed him to a small room without indicating he was free to leave.
- The detention exceeded the scope of a Terry investigative stop and amounted to an arrest unsupported by probable cause at the time of the confinement and luggage retrieval.
- Royer’s purported consent to the luggage search was tainted by the unlawful detention and could not justify the warrantless search.
- The marijuana was suppressed as the fruit of an unconstitutional seizure and search.
Legal Principles
- Police may approach an individual in a public place, ask questions, and request identification without a Fourth Amendment seizure if the person remains free to decline and leave.
- A seizure occurs when, considering all circumstances, a reasonable person would not feel free to leave due to police force or show of authority.
- An investigative detention under Terry must be limited in scope and duration and reasonably related to verifying or dispelling the officer’s suspicions; moving a suspect to a confined area and retaining travel documents may exceed Terry absent adequate justification.
- Consent to search obtained during an unlawful detention is generally invalid unless the causal connection is sufficiently attenuated.
Conclusion
The Court held that the airport stop escalated into an unlawful detention when officers retained Royer’s documents and moved him to a small room without probable cause, rendering his subsequent consent ineffective and requiring suppression of the marijuana found in his luggage.