Winfield v. Trottier
710 F.3d 49
2d Cir.2013Background
- Winfield, driving on I-89, is stopped for speeding by Trottier; Trottier seeks consent to search the car before verifying identity.
- Winfield exits the car and converses with Trottier; Trottier questions for items in the car and asks her to stand aside.
- Trottier pats down the son and searches the car after obtaining consent; he opens an envelope and reads its contents.
- The envelope contained a court document and a letter; Trottier finishes the search and issues a speeding ticket.
- Winfield and her husband sue under 42 U.S.C. § 1983 alleging Fourth Amendment violations; district court denies qualified immunity.
- The court reverses, holding Winfield’s consent did not extend to reading her mail, but Trottier is entitled to qualified immunity as the right was not clearly established.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether appellate jurisdiction lies to review the qualified-immunity denial on undisputed facts | Winfield argues the issue turns on fact-finding and is not appealable | Trottier contends the issue is a legal question of reasonableness | Yes; appellate jurisdiction exists for clearly established-law question under Mitchell v. Forsyth. |
| Scope of Winfield’s consent to search the car | Winfield's consent covered general search for contraband | Trottier argues consent could extend to items within the perceived scope | Consent did not extend to reading personal mail. |
| Whether reading the mail violated a clearly established Fourth Amendment right | Reading mail as part of search exceeds consent and violates rights | Right not clearly established; conduct reasonable under then-existing law | The right was not clearly established; Trottier entitled to qualified immunity. |
Key Cases Cited
- Florida v. Jimeno, 500 U.S. 248 (1991) (scope of consent determined by reasonable understanding; search must be within expressed object or implied scope)
- Anderson v. Creighton, 483 U.S. 635 (1987) (clearly established right must be sufficiently clear for reasonable official)
- Pearson v. Callahan, 555 U.S. 223 (2009) (two-prong qualified-immunity analysis; can address in any order)
- Mitchell v. Forsyth, 472 U.S. 511 (1985) (jurisdictional rule for appeal of qualified-immunity orders)
- X-Men Sec., Inc. v. Pataki, 196 F.3d 56 (2d Cir. 1999) (conduct is shielded if objectively reasonable under established rules)
- Brigham City, Utah v. Stuart, 547 U.S. 398 (2006) (reasonableness as Fourth Amendment touchstone)
- Taravella v. Town of Wolcott, 599 F.3d 129 (2d Cir. 2010) (qualified-immunity defense protects if acts were objectively reasonable)
- United States v. McWeeney, 454 F.3d 1030 (9th Cir. 2006) (search exceeding consent is violation; used as contrast in opinion)