Florida v. Harris and Florida v. ardines - Essay Example

? Critical Thinking Assignment: Florida v. Harris Florida v. Jardines Introduction Consistent in all global legislative systems, legal cases are initially sought out in lower and trial courts. Subsequently, the decisions are appealed and challenged in higher courts such as Supreme Court. Various concurring and dissenting opinions are revealed during the hearings of the cases and all circumstances are carefully accounted for before reaching final conclusion. References to past legal cases are very critical as situations of most of the cases resemble to those in older ones. This paper entails a detailed discussion and critical analysis of two separate legal cases which have mutually similar circumstances. Legal facts of case FLORIDA V. JARDINES This case revolved on deciding whether using a drug-sniffing dog on curtilage of an individual’s home, in hope of finding traces of illegal content, constitutes to meaning of ‘search’ as prescribed under the Fourth Amendment. Jardines’ house front porch was searched by police with Franky, a drug-sniffing dog, and a warrant was requested on basis of suspicious information gathered through this search. Later, marijuana and other related material were discovered from premises and Jardines was arrested and charged accordingly (Supreme Court of the United States [b] 3-12). FLORIDA V. HARRIS This case pertained to a similar situation whereby a police officer, Mr. Wheetley, pulled over a driver for a routine check-post stop and insisted on searching the vehicle after his trained K-9 dog indicated that side door handle reflects some traces of drugs content. Subsequently, only methamphetamine ingredients were found and Harris, the driver, was charged with its possession. Later out on bail, Harris ran into officer Wheetley again and a similar search was conducted but in vain. Harris filed a case to suppress the evidence on basis that the officer did not have probable cause for searching his trunk as the dog displayed incompetent performance. At the hearing, officer eventually confessed about expiry of certification and his lack of due diligence in maintaining updated records of dog’s performances and trainings (Supreme Court of the United States [a] 1-6). Court decisions FLORIDA V. JARDINES At the hearing of trial court, Jardines claimed that dog-sniffing investigation had no reasonable grounds and hence marijuana possession must be dispensed with. The trial court approved the motion which was subsequently reversed by the Florida Third District Court of Appeal. When petition was filed for scrutiny of this reversal, the Supreme Court nullified this decision and agreed to initial decision as given by trial court, suppressing that the trained-dog investigation falls under Fourth Amendment search and hence any warrant released on basis of information revealed in such search is itself void. FLORIDA V. HARRIS Initially, the trial court disapproved the motion to suppress on the grounds that officer had reasonable basis to conduct search. Harris entered an appeal against trial court’s decision and the intermediate state court also affirmed the same. However, subsequently the Supreme Court intervened and denied trial court’s decision and claimed that officer didn’t have probable cause to search vehicle in accordance with the definition under Fourth Amendment. It ruled out on the adequacy of reason given by the officer that the dog was adequately certified and trained. Later, the court itself established certain standards to test dog’s reliability and potential as it claimed that a wider range of evidence is required to indicate number of times the dog might have given a false alert in similar past situations. The Florida Supreme Court ordered that a complete set of records and exhibits for dog’s credentials must be presented for review prior to establishing its potential and credibility. It designed various tests to assess its capabilities and produced a rigorous checklist which the State was instructed to complete. Subsequently, all records proved that dog was reasonably capable and reliably for drug detection and hence, in the event of failure of Harris to prove the otherwise, Supreme Court finally disregarded judgment given by Florida Supreme Court and approved trial courts’ initial decision that officer had probable cause to conduct vehicle search (Supreme Court of the United States [a] 7-8). Concurring and dissenting opinions FLORIDA V. JARDINES Scalia delivered the opinion of the Court while Kagan, Ginsburg and Sotomayor concurred to this decision. They were of the view that officers intruded Jardines’ privacy while equipped with a device which helped them detect traces which they couldn’t possibly have in absence of dog (Supreme Court of the United States [b] 13-17). On the contrary, Alito, Roberts, Kennedy and Breyer gave a dissenting opinion, stating that there is no specific authority from previous cases which proves that being accompanied with a dog constitutes to a search without probable cause: this visit should be treated the same as any other legitimate visit by any police officer. Laying unnecessary emphasis on dog’s presence is irrational as dogs represent the largest proportion of domestic animals community. Also, they suggested that officer is capable of detecting any aroma himself, as Detective Pedraja claimed he did feel so, and conduct a search on these grounds which will not contribute to privacy invasion. Therefore, officers did not breach scope of the license that allows them to reach out front door of any household, as they used normal route, visited during normal hours and only stayed on porch for a very short period (Supreme Court of the United States [b] 18-29). FLORIDA V. HARRIS Justice Kagan delivered the opinion and a unanimous decision was reached as all of the appeal decisions and other jury members consented to the final conclusion. Although Judge Canady gave a dissenting decision, the majority of other committee members agreed to the decision and hence the rigid and detailed evidentiary requirements of law prevailed much above the irrational demands of probable cause (Supreme Court of the United States [a] 9-14). Contrast of both cases Both cases represent events where police forces went beyond the scope of search as defined and implied by the Fourth Amendment. The primary focus of these two cases was on the fact that the dogs used in the two scenarios do not belong to the typical domestic or neighbor’s pet category that one can claim to have taken out for a random stroll. These K-9 dogs are highly trained and represent one of the most powerful devices of special intelligence forces of the U.S. These dogs are capable of providing information to officers that is not easily detectable by normal human senses. Therefore, both the cases represent breach of definition of search without probable cause. However, decisions in both the cases were differently resolved by the Supreme Court, considering the mutually exclusive context and circumstances given in each scenario, such that it was considered essential to conduct a search of Harris’ vehicle while illegal to even run a dog-sniff search on porch of Jardines’ home. Conclusion It can be clearly observed from aforementioned facts and arguments that the two cases bear close resemblance to each other as the facts and contexts were distinct yet the legal provisions (Fourth Amendment) being affected and circumstances (drug-sniffing dogs) are very similar. It is fair to assume that decisions ruled by Supreme Court in each case are very rational and account for all the minute details attached to each case. Despite similarities between both the cases, the decisions ordered are mutually exclusive and differ according to context and facts of each case. References Supreme Court of the United States (2013a). Florida vs. Harris – Certiorari to the Supreme Court of Florida, No. 11-817, extracted from http://www.supremecourt.gov/opinions/12pdf/11-817_5if6.pdf, pp. 1-14. Supreme Court of the United States (2013b). Florida vs. Jardines – Certiorari to the Supreme Court of Florida, No. 11-564, extracted from http://www.supremecourt.gov/opinions/12pdf/11-564_5426.pdf, pp. 1-29. Read More