Supreme Court of the United States

California v. Byers

May 17, 1971402 U.S. 424

Summary

The Court vacated the California Supreme Court's judgment and held that California's requirement that a driver involved in a property-damage accident stop and provide a name and address does not violate the privilege against compulsory self-incrimination. The reporting duty is directed at the public generally, serves a primarily regulatory and noncriminal purpose, and requires disclosure that is not testimonial in the constitutional sense. Justices Black and Brennan, joined by other Justices, dissented, while Justice Harlan concurred in the judgment on different grounds and would limit the reach of prior self-reporting precedent.

Holding

  • Whether the reporting requirement creates substantial hazards of self-incrimination. The requirement does not violate the privilege against compulsory self-incrimination because it operates in an essentially noncriminal, regulatory setting, applies to the public generally rather than a group inherently suspect of criminal activity, and does not itself expose the driver to the kind of substantial self-incrimination risk recognized in criminally focused reporting schemes.
  • Whether stopping and providing a name and address is testimonial. Stopping at the accident scene and disclosing a name and address are not testimonial or communicative acts within the meaning of the privilege. They provide identification and physical or neutral information, even though the information may assist an investigation.

Docket 75

Cited authorities

  • 26 U.S.C. § 4401
  • Code Section 21750
  • Cal. Code §§ 20001-20012
  • Cal. Code §§ 1-42275
  • Cal. Code § 20002
  • Cal. Code § 20002
  • Cal. Code § 20012
  • 1966 Sup. Ct. Rev. 103

Cited by

Read full opinionPDF