United States v. Watson

423 U.S. 411 (1976).

One-Sentence Takeaway: Warrantless felony arrests made in a public place and based on probable cause are valid.

Summary: Police officers armed with probable cause but no warrant arrested Watson in a public restaurant for possession of stolen credit cards. The Supreme Court held that Watson’s warrantless arrest was valid and did not violate his Fourth Amendment rights.

In its opinion, the Court first based its holding on the fact that “[t]he cases construing the Fourth Amendment thus reflect the ancient common-law rule that a peace officer was permitted to arrest without a warrant for a misdemeanor or felony . . . if there was reasonable ground for making the arrest.”

The Court next determined that “[t]he balance struck by the common law in generally authorizing felony arrests on probable cause, but without a warrant, has survived substantially intact. It appears in almost all of the States in the form of express statutory authorization.”

Finally, the Court expressed its belief that the preceding principles indicated that “Congress has plainly decided against conditioning warrantless arrest power on proof of exigent circumstances.”

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