## Facts

- A reliable informant told a postal inspector that Henry Ogle Watson possessed stolen credit cards and had sent one to the informant to buy airline tickets.
- The informant delivered the stolen card to the inspector, and inspectors arranged a monitored meeting to obtain additional stolen cards.
- At a restaurant meeting, inspectors acted after a prearranged signal indicated Watson had more cards.
- Inspectors arrested Watson in public without a warrant, advised him of Miranda rights, and searched his person without finding cards.
- Inspectors requested permission to search Watson’s nearby car; Watson responded “Go ahead,” including after being told any evidence found would be used against him.
- A search of the car found an envelope under a floor mat containing two credit cards issued to other persons.
- Watson was convicted of possessing stolen mail after the district court denied his suppression motion.
- The Ninth Circuit reversed, ruling the warrantless arrest violated the Fourth Amendment and the car-search consent was coerced; the Supreme Court reversed.

## Issues

1. Whether the Fourth Amendment prohibits a warrantless public felony arrest supported by probable cause and authorized by statute when officers had time to obtain an arrest warrant.
2. Whether Watson’s consent to search his car was voluntary under the Fourth Amendment given the custodial setting and lack of advice that he could refuse consent.

## Decision

- The Court held the warrantless public arrest for a felony, based on probable cause and authorized by Congress for postal officers, did not violate the Fourth Amendment even if a warrant could have been obtained.
- The Court held Watson’s consent to search his car was voluntary under the totality of the circumstances and was not invalid solely because officers did not advise him he could refuse consent.
- The judgment of the Ninth Circuit was reversed, and the evidence was admissible.

## Legal Principles

- A warrantless public arrest for a felony is constitutionally reasonable when supported by probable cause; the Fourth Amendment does not impose a categorical rule requiring an arrest warrant whenever it is practicable to obtain one.
- Congressional authorization for warrantless felony arrests by federal officers is strong evidence of Fourth Amendment reasonableness, though probable cause remains required.
- Voluntariness of consent to search is assessed under the totality of circumstances; consent is invalid only if the person’s will is overborne or capacity for self-determination is critically impaired.
- Police are not required to give a specific warning that a person may refuse consent; knowledge of the right to refuse is a factor, not a prerequisite.

## Conclusion

The Court upheld a warrantless public felony arrest by postal inspectors supported by probable cause and statutory authority, and it sustained a consent-based automobile search where consent was voluntary under the totality of circumstances without any required warning of the right to refuse.


United States v. Watson, 423 U.S. 411 (1976)