Steven Dewayne Bond v. United States
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- February 27, 2024
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Facts of Case
Steven Dewayne Bond was traveling from California to Arkansas on a bus. A patrol entered the bus and started checking passengers’ legal (immigration) documents. On his way out, he decided to inspect the bags that had been placed in the overhead compartments. One of the bags belonged to Bond (the Petitioner); the agent decided to inspect the bag by squeezing it, discovering (feeling) a solid object inside. Petitioner eventually gave the agent permission to search its contents. As a result the brick was identified as methamphetamine with Bond being arrested. Bond argued that an illegal search was conducted violating the Fourth Amendment, while the District Court denied the statement. Petitioner was convicted of possession with the intention of distributing the illegal substance. The Fifth Circuit Court of Appeals supported the decision of the District Court, arguing that squeezing the object on the bus was not covered by the protection of the Fourth Amendment. The U.S. Supreme Court reversed the earlier ruling of the Fifth Circuit, arguing that squeezing Bond’s bag indeed was against the Fourth Amendment, which prohibits searches without a clear reason.
Procedural History
After his initial arrest, Bond claimed that Agent Cantu searched his bag illegally. The District Court rejected the arguments and Bond was found guilty of possession and possession with intent of selling the illegal substance; his sentence was ruled to be 57 months in jail. The Petitioner moved to appeal claiming that others on the bus could have placed the item in the bag. He also argued that Cantu squeezing the bag initially without Bond’s permission violated his Fourth Amendment rights. The argument was not acknowledged by the Court of Appeals, stating that the Agent was merely performing his job duties and had the right to inspect the bag.1 The Court of Appeals also did not find Bond’s claims reasonably relevant to the Fourth Amendment. Nevertheless, the U.S. Supreme Court denied the government’s view that, due to placing the bag in the open spot, the Petitioner reasonably expected a possibility of it being searched or inspected. Florida v. Riley (1989) and California v. Ciraolo (1986) were used to justify the decision of the Court, which stated that objects in direct public view can not be considered as protected.
Legal Issues
The U.S. Supreme Court attempted deciding or defining if the fact of squeezing a bag of the Petitioner could be regarded as a search requiring protection by the Fourth Amendment. In fact the Fourth Amendment states that “citizens have the right to be free and secure in their homes, belongings and protected against any unreasonable searches and seizures.”1 Using Florida v. Riley (1989) and earlier case of California v. Ciraolo (1986), the Petitioner’s luggage could be considered as the object, which one wants to keep while traveling and thus being protected under the Fourth Amendment.
Statement of Rule
Evidence was not obtained in good faith and the Bond’s rights protected under the Fourth Amendment were violated.
Policy
The laws cited in the case exist to protect citizens from unreasonable searches and seizures by police and other legal authorities.
Reasoning
The U.S. Supreme Court reversed decision of the Court of Appeals; Court ruled that Agent Cantu’s handling of Bond’s belongings constituted a violation of the Fourth Amendment principles. The Supreme Court held that the prior statement by the officials of the bag being placed in the overhead compartment did not mean that he forfeited his rights to privacy. The Petitioner did not have any expectation that his privacy rights would be violated. In any case, it is expected that the bag would have been touched or moved by the other passengers at one point or another. Florida v. Riley (1989)1 and California v. Ciraolo (1986) were used to justify the ruling2. In the Ciraolo and Riley, the court stated, the cases involved merely visual observation, while the present case involved physical manipulation (inspection through squeezing) of the object. Furthermore, the Supreme Court stated that even though passengers would expect that other individuals would come into contact with their bags, they did not expect that the contact would be in an searching or inspecting way.
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Holding
The Supreme Court used a two-part Fourth Amendment analysis. The first part aimed to determine if a person could actually expect the privacy on a public transportation like the bus, and whether such expectation could or should be regarded as reasonable. The Petitioner argued that even though he expected the passengers to come into contact with his bag, he did not expect that they could manipulate it in the way that Agent Cantu did. Therefore, he expected some reasonable level of privacy. The government countered this argument stating that by placing the bag in the overhead compartment and by bringing the bag on the bus as such the right to privacy could not be exercised. The Supreme Court, nevertheless, argued that Bond’s case differed from Ciraolo and Riley as the last only dealt with the visual aspect, but not the physical inspection that was performed by Agent Cantu. The U.S. Supreme Court declared that the Bond’s rights guaranteed by the Fourth Amendment were violated as the belongings placed in a bag were the personal items that one desires to keep in his possession.
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Writers
Dissent
Opinion with a 7-2 vote has been delivered by Chief Justice William H. Rehnquist. Supreme Court held that “Cantu’s squeezing Bond’s bag was considered as a violation of the Fourth Amendment’s principles.”1 The Chief Justice read that the Petitioner “had a privacy interest in his belongings,” which was also reasonable. The clear distinction was drawn between visually checking the bag and squeezing or touching it by the Agent. Justice Breyer and Justice Scalia, dissented, observing that there is no “reasonable expectation” that other travelers would not touch or squeeze (intentionally or not) luggage in a bus.
Bibliography
Bond v. United States, 529 U.S. 334 (2000).
https://casetext.com/analysis/bond-v-us-case-brief
California v. Ciraolo, 476 U. S. 207 (1986).
https://supreme.justia.com/cases/federal/us/476/207/
Florida v. Riley, 488 U. S. 445 (1989).
https://supreme.justia.com/cases/federal/us/488/445/
Kim, Jonathan. “Fourth Amendment.” Cornell Law School, June 2017.
https://www.law.cornell.edu/wex/fourth_amendment
What exactly made Steven Dewayne Bond to be arrested?
Steven Dewayne Bond was apprehended during inspection of a bus that he was traveling from California to Arkansas. A patrolling agent found a bulging bag, squeezed it and felt that the contents inside were solid. When the bag was unzipped upon permission of the owner, methamphetamine was discovered inside it.
What kind of legal claim did the mentioned Bond make about searching?
Bond alleged that bag squeezing without his initial consent that was conducted already infringed his rights stipulated in the Fourth Amendment that cannot allow unreasonable searches and seizures.
Which strategies did courts use when they countered Bond's claims first of all?
The District Court disagreed with Bond’s claim and sentenced him for the offenses of possession and intent to distribute the unlawful substance. The Fifth Circuit Court of Appeals upheld the decision made lower courts where it argued that the search was beyond the coverage of the Fourth Amendment.
On which grounds did the U.S. Supreme Court in fact overturn the judgments given their below?
The Supreme Court of the United States cut against the rulings of the lower courts favoring Bond that tube pressing the bag of Bond is a constraint to the Fourth Amendment. Therefore, the Court highlighted the cases in which such a precise action as a bag search at Bond is not justified at all as we cannot talk about the public transport setting for this case.
Why the court was taking the precedent in which it can be referred to Bond’s case and how it was applied to her case?
Utilizing the Florida v. Riley case (1989) and California v. Ciraolo (1986), the Supreme Court argued that although the two cases involved visual inspection from public positions, the ruling in Bond’s case centered around physical manipulation of the personal items. The Supreme Court noted that such physical touch without legitimate causes breaks forth the Fourth Amendment because it surpasses common observation from far distances or incidental touches which are usually made in open spaces.
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