Horton v. California

Following is the case brief for Horton v. California, 496 U.S. 128 (1990)

Case Summary of Horton v. California:

  • Petitioner moved to suppress evidence of an armed robbery that was discovered in plain view by an officer during execution of a search warrant.  The officer expected to find those items, however, so the plain view discovery was not inadvertent.
  • The trial court refused to suppress the evidence, and petitioner was convicted of armed robbery.
  • The state appeals court affirmed the trial court’s decision on the motion to suppress.  The state supreme court declined review.
  • The U.S. Supreme Court affirmed.  It held that a warrantless seizure of an item in plain view does not violate the Fourth Amendment, even though the discovery in plain view was not inadvertent.

Horton v. California Case Brief

Statement of the Facts:

  • The Crime.

Erwin Wallaker, treasurer of the San Jose Coin Club, had just returned home from the Club’s annual show when he was attacked, restrained, and robbed by two masked men.  Wallaker was able to determine the identity of one of the robbers based on his voice.  That robber was petitioner Horton, who had attended the Club’s show that evening.

The police officer investigating the crime, having determined that there was probable cause to search petitioner’s home for proceeds of the crime and the weapons used, applied for a search warrant.  The magistrate issued a search warrant but only authorized a search for the proceeds of the crime, not the weapons.

  • Execution of the Warrant and Plain View Discovery.

Based on the warrant, the officer searched petitioner’s home without finding the proceeds of the robbery.  However, during the search he found, in plain view, weapons and other evidence connecting petitioner to the crime.  The officer later testified that he was interested in finding other evidence of the crime during the search.  Accordingly, the discovery of the weapons and other evidence was not inadvertent.

Procedural History:

  • Petitioner moved to suppress the weapons and other evidence seized by the officer.  The trial court denied that motion.  Petitioner was later convicted of armed robbery at trial.
  • The California Court of Appeal affirmed.  It held that the case of Coolidge v. New Hampshire, 403 U.S. 443 (1971), was not binding precedent because it was a plurality decision.  Therefore, the fact that the discovery of evidence was not inadvertent does not require suppression of the evidence.
  • The California Supreme Court denied review.
  • The U.S. Supreme Court granted certiorari because of a possible conflict on how to interpret the “plain view” doctrine.

Issue and Holding:

Does the Fourth Amendment forbid the warrantless seizure of items in plain view if the discovery of those items was not inadvertent?  No.

Judgment:

The decision of the California Court of Appeal is affirmed.

Rule of Law or Legal Principle Applied:

The Fourth Amendment does not forbid the warrantless seizure of items in plain view even if the discovery of the items was not inadvertent.  Inadvertence is not a mandatory requirement for a valid seizure of items in plain view.

Reasoning:

  • Two requirements for plain view seizures.

A valid seizure of items in plain view without a warrant has two requirements:  (i) the incriminating character of the item must be immediately apparent; and (ii) the officer must be in a place to lawfully access the item.  In this case, both requirements were satisfied.  The weapons and other items were obviously connected to the robbery, and the officer was legally in petitioner’s home based on the warrant.

  • Courts should look to objective conduct, not officer’s subjective motives.

There are two reasons why inadvertence is not a mandatory condition of plain view seizures. First, courts should strive to apply objective measures of police conduct.  Therefore, inquiring into an officer’s subjective motives — e.g., that the officer knew he would also find weapons during a search for proceeds of the robbery — is disfavored.  Just because an officer expects to find something does not invalidate the seizure if he is within the parameters of the warrant he is enforcing.

  • Failing to require inadvertence does not transform particularized warrants into general warrants.

Second, particularized warrants do not become general warrants by failing to require inadvertence in plain view seizures.  In this case, the search’s scope did not change because weapons were omitted from the warrant issued by the magistrate.

Dissenting Opinion (Brennan):

The Fourth Amendment requires search warrants to specify the place to be searched and the items to be seized.  Therefore, unless a plain view seizure is inadvertent, it is beyond the scope of the particularized warrant and, thus, a violation of the Fourth Amendment.

Significance:

Horton v. California weakened the need for inadvertence in plain view seizures.  While Justice Stevens, writing for the majority, tried to emphasize that inadvertence is typically part of plain view seizures, taking away an inadvertence requirement does increase the danger that a particularized warrant could become a general one.

Student Resources:

https://supreme.justia.com/cases/federal/us/496/128/case.html

https://www.oyez.org/cases/1989/88-7164

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