Atwater v. Lago Vista
Citation and Court
532 U.S. 318 (2001) — Supreme Court of the United States
Facts
Gail Atwater was driving her pickup truck in Lago Vista, Texas when a police officer pulled her over because her children were not wearing seatbelts, a violation of Texas law carrying a maximum fine of $50. The officer handcuffed Atwater, placed her in his squad car, and took her to the police station, where she was booked, photographed, and held for about an hour before being released on bond.
Issue
Does the Fourth Amendment forbid a warrantless arrest for a minor criminal offense, such as a misdemeanor seatbelt violation punishable only by a fine?
Holding
No; the Fourth Amendment does not prohibit a warrantless arrest for even a very minor criminal offense, as long as it is an offense for which the person could be arrested under state law.
Rule / Doctrine
If an officer has probable cause to believe an individual has committed even a very minor criminal offense in the officer’s presence, the officer may, consistent with the Fourth Amendment, arrest the offender.
Significance
Atwater grants police very broad discretion to arrest for any criminal offense, no matter how minor, as long as probable cause exists. It prevents courts from engaging in case-by-case balancing of the severity of the offense against the intrusiveness of a custodial arrest, choosing instead a bright-line rule favoring officer discretion.