Facts
- A series of burglary-sexual assaults occurred in Punta Gorda, Florida; police recovered latent fingerprints from a victim’s bedroom doorknob believed to be the assailant’s.
- Police focused on Joe Hayes as a principal suspect and went to his home without a warrant to obtain fingerprints.
- Officers spoke with Hayes on his front porch and sought to take him to the police station for fingerprinting.
- When Hayes hesitated, an officer said they would arrest him; Hayes stated he would rather go to the station than be arrested.
- Officers seized a pair of tennis shoes visible on the porch and transported Hayes to the station, where they took his fingerprints.
- After the fingerprints matched those recovered from the crime scene, Hayes was formally arrested and later convicted.
- State appellate findings included that Hayes did not consent to the stationhouse trip and that probable cause did not exist until after the fingerprints were obtained.
Issues
- Whether the Fourth Amendment permits police, without consent, probable cause, or prior judicial authorization, to transport a suspect to a stationhouse for investigative fingerprinting based only on reasonable suspicion.
- Whether fingerprints obtained through such a stationhouse detention must be excluded as the fruit of an unlawful seizure.
Decision
- The Supreme Court reversed the state court’s judgment affirming Hayes’s conviction.
- The Court held that transporting Hayes from his home to the station and detaining him for fingerprinting, without probable cause, consent, or judicial authorization, violated the Fourth Amendment.
- The fingerprints obtained during the unlawful detention were inadmissible as fruits of the illegal seizure.
Legal Principles
- A nonconsensual stationhouse detention for investigative fingerprinting is sufficiently like an arrest to require probable cause, absent prior judicial authorization.
- The limited scope of a Terry stop does not extend to transporting a suspect to the station for fingerprinting on reasonable suspicion alone.
- Fingerprint evidence obtained through an unconstitutional detention is subject to exclusion as fruit of the unlawful seizure.
- The Fourth Amendment may permit narrowly limited fingerprint procedures with prior judicial authorization and safeguards, but such conditions were not present here.
Conclusion
The Court held that police violated the Fourth Amendment by threatening arrest and transporting a suspect to the station for fingerprinting without consent, probable cause, or judicial authorization, requiring suppression of the resulting fingerprints.