Supreme Court of the United States

District of Columbia v. Wesby

January 22, 2018583 U.S. 48

Summary

The Supreme Court unanimously reversed the D.C. Circuit, holding that officers had probable cause to arrest 21 partygoers for unlawful entry because the totality of the circumstances—the near-barren house converted into a makeshift strip club, the partygoers' scattering and hiding at the sight of police, their vague and implausible stories, and 'Peaches'' admitted lie—supported a reasonable inference that they knew they lacked permission to be in the house. The Court further held that the officers were entitled to qualified immunity because, even assuming no actual probable cause, they reasonably but mistakenly concluded that probable cause was present, and no precedent found a Fourth Amendment violation under similar circumstances. Because probable cause defeats all of the partygoers' claims, the District and its officers were entitled to summary judgment. Justice Sotomayor concurred in part and in the judgment, objecting that the Court need not have reached the merits of the probable-cause question, and Justice Ginsburg concurred in the judgment in part while questioning whether an officer's reason for acting should ever factor into the Fourth Amendment inquiry.

Holding

  • Whether the officers had probable cause to arrest the partygoers for unlawful entry.. Yes. Considering the totality of the circumstances—the vacant condition of the house, the partygoers' conduct, their scattering and hiding at the sight of police, their vague and implausible answers, and Peaches' lying and evasive behavior—a reasonable officer could conclude that the partygoers knew they did not have permission to be in the house.
  • Whether the officers were entitled to qualified immunity even assuming they lacked actual probable cause.. Yes. Even assuming the officers lacked actual probable cause, they are entitled to qualified immunity because they reasonably but mistakenly concluded that probable cause was present; neither the panel majority nor the partygoers identified a single precedent finding a Fourth Amendment violation under similar circumstances, and this is not an 'obvious case' where a body of relevant case law is unnecessary.

Docket 15-1485

Cited authorities

Cited by