October 11, 2011
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?
3 thoughts on “Wilson v. Layne (1999)”
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October 13th, 2011 at 4:38 pm
Regarding to whether I feel this is a Fourth amendment violation I believe it is. For as stated in the Fourth Amendment, “The right of the people to be secure in their persons, houses, papers, and effects, against unreasonable searches and seizures, shall not be violated” Thus, I think in Wilson v. Layne, the Fourth Amendment was indeed violated, especially due to the unnoted “media ride-along” not stated in the warrants. Regarding the legal precedent this case would have ruled in favor of Wilson in 2011. Yet, there was no specific law about “media ride-alongs” in 1992. Now, the law is very with reporters’ having equal access to information.
October 13th, 2011 at 5:52 pm
I do feel that the action carried out violated the fourth amendment. It seems to me that the amendment is there so that people do not go through this kind of ordeal unless there is reason to believe they are guilty., (hence the obtaining of the warrant). While the warrant was issued, it was not issued for the two whom experienced the raid.
When I searched for any updates I found that nothing has changed, but because of this case reporters are not permitted to ride along with cops anymore.
I don’t really see how it’s newsworthy to tape an arrest warrant being served, however it is similar to public record. So I would say I do not think this is illegal, however I think its not really worth the harm it will do to the potentially innocent person being served the warrant.
October 16th, 2011 at 10:48 am
I feel that the Fourth Amendment was indeed violated by the Media “Ride-along” and that its a pretty obvious violation based on the language of the Amendment itself and common sense. But as I read over the summary here, it seemed that most of the courts spent their time trying to decide based on non-existent precedent. Yes it’sd true that you dont want to cause a chilling effect or violate the First Amendment with the Media, but this example seemed like a straight forward violation of the Fourth and the Court spent a lot of time figuring out which amendment was more important in this situation. Seemed like they made it more complicated than it needed to be, but than this is Law.