Hiibel v. Sixth Judicial District Court of Nevada, Humboldt County, 542 U.S. 177 (2004)
After receiving a call reporting a fight between a man and a woman of Grass Valley Road in Nevada, a deputy sheriff was dispatched to the scene. Upon arrival, the deputy observed a pick-up truck parked on the side of the road with a woman sitting inside the truck and a man standing outside of it. The deputy approached the man and informed him that he was here to investigate a reported assault. The man denied being involved in any assault or having done anything wrong. The deputy, observing that the man seemed intoxicated, asked if he had any identification on him. The man refused to provide identification and further asked the deputy why he needed to see it. The officer responded that as part of his investigation he needed to see his Identification to determine who he was and why he was present at the scene. After 11 requests to produce some form of identification, the man was placed under arrest and charged with obstructing a police officer in the performance of his legal duty. The man arrested was ultimately verified as Larry Hiibel. After a short trial before the Justice Court of Union Township, Hiibel was convicted of obstruction and fined U.S. $250.
Procedural History
Hiibel appealed his conviction to the Sixth Judicial District Court arguing that the law to which he was convicted of violating unconstitutional in two aspects. First, it violated his Fourth Amendment right against an unreasonable search and seizure by the state. Second, it violated his Fifth Amendment right to remain silent. The Sixth Judicial District Court rejected Hiibel’s argument, finding that it was not unreasonable for the deputy to ask for identification considering the call reporting an assault, the fact that Hiibel was seemed to be the diver of the car parked at the scene and the fact that he seemed intoxicated.
Hiibel, then appealed the Sixth Judicial District Court’s to the Nevada State Supreme Court, arguing that the Sixth Judicial District Court had erred in affirming the trial court conviction. The Nevada State Supreme Court, while acknowledging the right of all citizens to “be let alone” stated the there are limits to the privacy that people can enjoy. According the court, those limits are limited by whether or not it is reasonable for the state to intrude upon one’s privacy. In the court’s analysis, the deputy’s intrusion on Hiibel’s privacy was reasonable under the specific circumstance of that particular incident. Consequently, the affirmed the Sixth Judicial District Court’s holding on Hiibel’s Fourth Amendment argument. As to result of the Nevada State Supreme Court’s decision, Hiibel petitioned the U.S. Supreme Court for to review their decision as well as the decision of the Sixth Judicial District Court. In 2003, the Court agreed to review the case.
Issues(s)
Was Hiibel’s arrest for failing to provide his identification or tell the arresting deputy who he was a unreasonable search under the Fourth Amendment and a violations of his Fifth Amendment privilege to remain silent so as not to incriminate himself.
Decision
In a 5-4 majority opinion authored by Associate Justice Anthony Kennedy, the Court affirmed the rulings by both the Nevada State Supreme Court and the Sixth Judicial District Court. Under the Court’s analysis, the Nevada law that Hiibel was convicted of was constitutional as were the actions of the deputy.
Reasoning
According to the Court, application of the Fourth Amendment requires a balancing of the individual’s right to privacy and the state’s interest in safety and ensuring security of the community. In this case, Hiibel under the Fourth Amendment had a right not to say who he was but the officer, based on the circumstances also had a reasonable right to inquire about his identity. The key fact however was that the arrest was under a Nevada state law. States are allowed to impose additional requirements that may tip the balance in favor of the state. According to the Court, the state’s extra requirements, that an officer were reasonable under the Constitution because they simply required a suspect to give a name rather than actual identification. Furthermore, the Court held that there was no evidence that simply giving an officer one’s name is incriminating. Accordingly, the Court rejected both arguments and confirmed Hiibel’s conviction.
Separate Opinions
Justice Breyer and Stevens authored separate dissents. Justice Breyer argued in his dissent that Court precedent held that it was legal for a person to refuse to answer questions when stopped by law enforcement. Moreover, Breyer argued that he did not see any way the refusing to give a one’s name significantly interfered with the officer’s official duties (Hiibel). In his dissent Justice Stevens argued that forcing Hiibel to identify himself or be arrest was unconstitutional on the grounds that it violated his right against self-incrimination. According to Stevens, Hiibel was fully within his right to refuse to identify himself.
Impact of Discretion
The impact of the Court’s holding is that police can arrest a suspect simply for failing to identify themselves if they have reasonable suspicion that the individual was involved in or about to be involved in a criminal activity.
Works Cited
Sixth Judicial District Court of Nevada, Humboldt County, 542 U.S. 177 (2004). Supreme Court of the United States. http://caselaw.findlaw.com/us-supreme-court/542/177.html
