Florida v. Thomas
Encyclopedia
Florida v. Thomas, , was a United States Supreme Court
case decided in 2001. The case brought to the court concerned the extent of the Court's earlier decision in New York v. Belton
, concerning whether a person was in custodial custody
, a determination central to allowing evidence seized in an automobile search to be presented in trial. However, the Court unanimously dismissed the case because the decision of the Florida state courts was not "final".
. Thomas was arrested thereafter when a search on his license showed an outstanding warrant
. One officer proceeded to take him inside the house while another searched his car, finding methamphetamine
. He was indicted for possession. At his trial, he moved to suppress the evidence
, which was subsequently granted by the trial judge. In reversing, an intermediate appellate court found the search valid under New York v. Belton
. In Belton, the U.S. Supreme Court established a "bright-line" rule permitting an officer who has made a lawful custodial arrest of a car's occupant to search the car's passenger compartment as an incident of the arrest. In reversing the intermediate court of appeals, the Florida Supreme Court
held Belton did not apply because it is limited to situations where the officer initiates contact with a vehicle's occupant while that person remains in the vehicle. The Supreme Court granted review. It would only be a few months before the ultimate decision, where they would dismiss the case.
authored by Chief Justice William H. Rehnquist, the Court dismissed the writ of certiorari for want of jurisdiction. Rehnquist wrote that the Florida Supreme Court's decision did not fit any of the categories where the Court "treated state-court judgments as final for jurisdictional purposes although there were further proceedings to take place in the state court." Thus, the Court concluded that the Florida Supreme Court's decision was not final. This was partly based on a doctrine from the Cox decision
which decided that certain decisions were not 'final' when the trial proceedings had not been completed.
Supreme Court of the United States
The Supreme Court of the United States is the highest court in the United States. It has ultimate appellate jurisdiction over all state and federal courts, and original jurisdiction over a small range of cases...
case decided in 2001. The case brought to the court concerned the extent of the Court's earlier decision in New York v. Belton
New York v. Belton
In New York v. Belton, 453 U.S. 454 , the United States Supreme Court held that when a police officer has made a lawful custodial arrest of the occupant of an automobile, the officer may, as a contemporaneous incident of that arrest, search the passenger compartment of that automobile...
, concerning whether a person was in custodial custody
Custody
Custody may refer to:* Legal custody* Child custody, a description of the legal relationship between a parent and child* Police custody or detention, a lawful holding of a person by removing their freedom of liberty...
, a determination central to allowing evidence seized in an automobile search to be presented in trial. However, the Court unanimously dismissed the case because the decision of the Florida state courts was not "final".
Background
Police officers went to Robert Thomas' home, investigating possible marijuana sales at his Florida home. While this was going on, Thomas drove up to his house in his car. An officer asked him for his name and identificationDriver's license
A driver's license/licence , or driving licence is an official document which states that a person may operate a motorized vehicle, such as a motorcycle, car, truck or a bus, on a public roadway. Most U.S...
. Thomas was arrested thereafter when a search on his license showed an outstanding warrant
Warrant (law)
Most often, the term warrant refers to a specific type of authorization; a writ issued by a competent officer, usually a judge or magistrate, which permits an otherwise illegal act that would violate individual rights and affords the person executing the writ protection from damages if the act is...
. One officer proceeded to take him inside the house while another searched his car, finding methamphetamine
Methamphetamine
Methamphetamine is a psychostimulant of the phenethylamine and amphetamine class of psychoactive drugs...
. He was indicted for possession. At his trial, he moved to suppress the evidence
In limine
Motion in limine is a legal written "request" or motion to a judge which can be used for civil or criminal proceedings and at the State or Federal level. A frequent use is at a pre-trial hearing or during an actual trial requesting that the judge rule that certain testimony regarding evidence or...
, which was subsequently granted by the trial judge. In reversing, an intermediate appellate court found the search valid under New York v. Belton
New York v. Belton
In New York v. Belton, 453 U.S. 454 , the United States Supreme Court held that when a police officer has made a lawful custodial arrest of the occupant of an automobile, the officer may, as a contemporaneous incident of that arrest, search the passenger compartment of that automobile...
. In Belton, the U.S. Supreme Court established a "bright-line" rule permitting an officer who has made a lawful custodial arrest of a car's occupant to search the car's passenger compartment as an incident of the arrest. In reversing the intermediate court of appeals, the Florida Supreme Court
Florida Supreme Court
The Supreme Court of the State of Florida is the highest court in the U.S. state of Florida. The Supreme Court consists of seven judges: the Chief Justice and six Justices who are appointed by the Governor to 6-year terms and remain in office if retained in a general election near the end of each...
held Belton did not apply because it is limited to situations where the officer initiates contact with a vehicle's occupant while that person remains in the vehicle. The Supreme Court granted review. It would only be a few months before the ultimate decision, where they would dismiss the case.
Opinion of the Court
In a unanimous opinionMajority opinion
In law, a majority opinion is a judicial opinion agreed to by more than half of the members of a court. A majority opinion sets forth the decision of the court and an explanation of the rationale behind the court's decision....
authored by Chief Justice William H. Rehnquist, the Court dismissed the writ of certiorari for want of jurisdiction. Rehnquist wrote that the Florida Supreme Court's decision did not fit any of the categories where the Court "treated state-court judgments as final for jurisdictional purposes although there were further proceedings to take place in the state court." Thus, the Court concluded that the Florida Supreme Court's decision was not final. This was partly based on a doctrine from the Cox decision
Cox Broadcasting Corp. v. Cohn
Cox Broadcasting Corp. v. Cohn, 420 U.S. 469 was a United States Supreme Court case involving freedom of the press. The case determined that a Georgia law prohibiting the release of a rape victim's name was unconstitutional...
which decided that certain decisions were not 'final' when the trial proceedings had not been completed.
See also
- CertiorariCertiorariCertiorari is a type of writ seeking judicial review, recognized in U.S., Roman, English, Philippine, and other law. Certiorari is the present passive infinitive of the Latin certiorare...
- Jurisdiction issues in American law
- Motor vehicle exception in Fourth Amendment LawMotor vehicle exceptionThe motor vehicle exception was first established by the United States Supreme Court in 1925, in Carroll v. United States. The motor vehicle exception allows an officer to search a vehicle without a warrant as long as he or she has probable cause to believe that evidence or contraband is located...
- Probable causeProbable causeIn United States criminal law, probable cause is the standard by which an officer or agent of the law has the grounds to make an arrest, to conduct a personal or property search, or to obtain a warrant for arrest, etc. when criminal charges are being considered. It is also used to refer to the...