United States v. Watson
2015 U.S. App. LEXIS 8377
| 2d Cir. | 2015Background
- Officers Vaccaro and Valentino were assigned to locate Chauncey Butler, with a photo and an I-Card detailing Butler’s pedigree information and probable arrest for robbery in the third degree.
- Watson, a Black man 6’2” and about 180 pounds, was observed around 5:00 p.m. and perceived to resemble Butler; the officers exited their car after a hand signal suggesting a drug transaction.
- Watson was stopped, identified, and searched; Vaccaro claimed Watson’s movements suggested a drug sale and, upon seeing a gun butt, frisked Watson and found a firearm and 27 bags of crack cocaine.
- Watson denied being Butler and produced valid ID; his companion Strickland was also detained; Watson contends there was no third- party drug transaction and his gun was concealed.
- The district court ruled the search unconstitutional: no reasonable basis to search Watson if he was Butler (or to search him at all given the circumstances); on appeal the Second Circuit affirmed, rejecting the government’s arguments based on appearance and subjective belief.
- The court did not need to definitively rule on whether the third-degree robbery charge would have justified a search even if Watson resembled Butler, as the found facts did not support a reasonable suspicion to search.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Was there a reasonable suspicion to stop Watson as Butler? | Watson looks like Butler might be enough to justify the stop. | The resemblance between Watson and Butler supports reasonable suspicion or confirmation. | No; the court affirmed, holding no reasonable basis to search, given dissimilarities and lack of corroborating evidence. |
| Does the officer's subjective belief about Watson being Butler matter to Fourth Amendment analysis? | Subjective belief may be relevant to the stop/search. | Subjective beliefs are generally irrelevant to probable cause/suspicion analysis. | Not necessary to reach this issue for decision; court affirmed on objective grounds. |
Key Cases Cited
- United States v. Esiek e, 940 F.2d 29 (2d Cir. 1991) (stop-and-frisk timing tied to verification of suspicion)
- Rodriguez v. United States, 135 S. Ct. 1609 (U.S. 2015) (limits on detention to the time needed to verify or dispel suspicion)
- United States v. Montoya de Hernandez, 473 U.S. 531 (1985) (reasonableness of detentions during investigations)
- Devenpeck v. Alford, 543 U.S. 146 (2004) (arresting officer's state of mind is irrelevant to probable cause)
- Sibron v. New York, 392 U.S. 40 (1968) (limitations on evidence and purpose of stops)