Wilson V. Layne (1999)

1. Facts of Case

In the Supreme Court Case Wilson v. Layne , in May 24, 1999 the court looked at a case appealed in lower courts, thus sent to The United States Court of Appeals for the Fourth District.  In April of 1992, the Circuit Court for Montgomery County issued three arrest warrants for Dominic Wilson, one for each of his probation violations. He was classified under the authorities as a violent criminal and a danger. Around 6:35 a.m. deputy federal marshals and local sheriff deputies, a Washington Post reporter and cameraman went to make their arrest at Wilson’s parents household. They entered the household, though none of the warrants stated that the media could be present and enter the household. Dominic was not even there. Various pictures were taken of the confrontation between officers and the father of Dominic Wilson. Yet, the Washington Post did not publish the pictures taken at the Wilson’s home. Geraldine and her husband Charles sued the law enforcement officials in their personal capacities for money damages under Bivens v. Six Unknown Fed. Narcotics Agents, 403 U. S. 38. The district agreed their Fourth Amendment Rights had been violated, but the district court denied a motion of summary judgment on their ruling of qualified immunity. At the Court of Appeals, the case was heard twice and the court declined on deciding whether law enforcement violated the Fourth Amendment. They stated that no court to this time had made a ruling or precedent was not clearly established, therefore granting qualified immunity.  Government officials have a shield of liability, holding plaintiff’s to a higher burden of proof.

2. Legal Issue

Were the officers’ actions in bringing the media to observe and record the attempted implementation of the arrest warrant a violation of the Fourth Amendment? Even if the law in 1992 was not clear in establishing laws of “media ride along”?

3. Decision

The Supreme Court ruled that while carrying out an arrest warrant in a private home, a “media ride along” does violate the Fourth Amendment. Yet, because the state of the law was not clearly established at the time, the officers are permitted to use the defense of qualified immunity.

 

4. Analysis

The court reached the decision that although Fourth Amendment rights were violated, due to the time and law uncertainty that law enforcement immune in Wilson v. Layne through applying basic principles of the Fourth Amendment to situations, like those similar to the case, where police entered a home under and arrest warrant to take a suspect into custody and noted that although common-law tradition during the time it was drafted was irrelevant to the present day circumstances of the case. Thus, the Supreme Court decided that an arrest warrant founded on probable cause completely carries with it a notion to allow law enforcement to enter where they feel a suspect may be present at. Making a decision peering at the court ruling in United States v. Lanier in 1997, the court stated that for the purposes of qualified immunity meaning, the official must be incredibly clear that a reasonable official would understand what he is doing is a violation of rights. Therefore, they are in question concerning what’s previously been deemed unlawful, which must be apparent. In this case, they found that at the time of the incident in Wilson v. Layne there was no judicial opinion present concerning “media ride-alongs”, furthermore, leading to the law enforcement’s immunity in this case.

5. Questions

1. Do you find this case, contrary to the court’s ruling and facts, in violation of the Fourth Amendment?

2. How has legal precedent changed since this case was decided in 1999?

3. Do you think news media should have access to the issuing of warrants to          violent criminals?