State v. Williams, 62 So. 3d 244

Williams was arrested for public intoxication under New Orleans Municipal Code 54-405 after officers observed him intoxicated and stumbling near Dupre and Orleans.
A search incident to arrest yielded five individually wrapped pieces of crack cocaine in a sock on Williams's right foot.
The trial court denied Williams's motions to suppress and found probable cause to support the charge.
Williams pled guilty pursuant to Crosby; the court sentenced and later re-sentenced on a multiple-bill proceeding.
Williams filed a supervisory writ challenging the suppression ruling; this Court granted in part to allow an appeal.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the arrest for public intoxication was lawful	State: officers had probable cause to believe he endangered self or others.	Williams: no danger shown; arrest for public intoxication unlawful.	Arrest supported by probable cause; search incident to arrest affirmed.

State v. Parker, 931 So.2d 353 (La. 2006) (arrest for public intoxication; review of probable cause; good-faith standard)
State v. Wells, 45 So.3d 577 (La. 2010) (good-faith and likelihood of arrest; intoxication alone not sufficient)
State v. Hawkins, 923 So.2d 763 (La. App. 4 Cir. 2006) (illegal arrest where intoxication did not show danger to public)
State v. Smiley, 729 So.2d 743 (La. App. 4 Cir. 1999) (public intoxication arrest requires danger component; no probable cause)
State v. Pham, 839 So.2d 214 (La. App. 4 Cir. 2003) (arrest standard: reasonable cause to believe not beyond; deference to trial court)