Cupp v. Murphy
Citation: Cupp v. Murphy 412 U.S. 291 (1973)
Merits of the Case
According to the circumstances of this case, a defendant named Daniel Murphy was charged with having murdered his wife. The couple did not prove to have hit it off for a long time and therefore, they lived separately. The story tells that the victim was murdered by means of suffocation in the territory of her home which was located in Portland City. The detectives found avulsed wounds and numerous bruises on the victim’s neck, however the investigation team assumed that someone out of the circle of persons known to Mrs. Murphy had killed her since the apartment and the victim’s room demonstrated no characteristics of burglary (412 U.S. 291 (1973).
Shortly after the incident, the victim’s husband, Mr. Murphy, called the police department responsible for the investigation of crimes in the territory of the city mentioned above and thus headed to that department to give testimony. Curiously enough, Mr. Murphy appeared in the Portland police department without any official requests for appearance and told where he had been and what he had done on the day of crime. In the process, the police detectives saw some suspicious trace on the defendant’s finger which resembled a blood trace. Due to assuming that this blood might belong to Murphy’s wife, and being aware of the evanescence nature of such evidence if not taken, the detectives requested Mr. Murphy if they could subject him to the fingernail scrapings procedure. The suspect did not allow them to conduct such a procedure voluntarily and thus they took the specimen forcibly, without a warrant and official arrest followed (412 U.S. 291 (1973).
The analysis outcome demonstrated that the suspect’s “fingernail scrapings” had blood and skin specimen of his wife killed and that medical result was admitted for the jury’s consideration in the court of the first instance. Consequently, the court of the first instance ruled that Mr. Murphy must be imprisoned for the second-level homicide of his wife. The defendant brought an appellate claim with the Oregon Court of Appeals and was denied of the right to rehearing. The aforementioned appellate court ruled that the medical result (meaning, the “fingernail scrapings”) (412 U.S. 291 (1973) was fully consistent with the requirements of the Fourth and Fourteenth Amendments the defendant referred to as the basis for reconsideration.
Owing to this decision, the representatives of Mr. Murphy petitioned for “federal habeas corpus relief” which was not granted by the District Court. However, the appellate court set aside the District Court’s holding and ruled that the taking of the specimen was not consistent with the Constitution’s provisions. Resting on this result, the defendant petitioned to the Supreme Court of the United States to obtain the certiorari (412 U.S. 291 (1973).
Issue Before the Court
When the defendant’s claim was filled with the Supreme Court, it was tasked to determine whether the taking of the specimen, as a type of probable search, was consistent with the Fourth and Fourteenth Amendments to the Constitution or not, given that Mr. Murphy was not officially arrested and was subjected to the procedure without the warrant being issued.
Argument
A. Reasoning
The Supreme Court decided that the medical procedure at issue did not constitute a legal fact which should be declared unconstitutional because the “fingernail scrapings” could be fairly categorized as the “evanescent evidence” basing on the similar case law. Such evidence is allowed to be taken without a warrant in the instances where police detectives are certain that a suspect may be reasonably expected to intend and try to destroy traces of crime and his relation to it and where, as a consequence of this unofficial procedure, a suspect’s constitutional rights are unlikely to be violated because such actions of the law enforcement authorities shall not be considered as a considerable intervention into a person’s life (412 U.S. 291 (1973).
Equally important, while hearing the issue of this medical procedure’s constitutionality, the Supreme Court also assumed that it must consider the absence or presence of “probable cause” at the moment when the investigation team arrived at the conclusion to take this specimen. The judges resorted to the holding in the case of Davis v. Mississippi stating that Davis fingerprints were taken from him unlawfully since the police officials did not have “probable cause” to conduct such a procedure. However, the presiding judge in the case of Davis ruled that the taking of fingerprints did not represent the intervention into a person’s life to be regarded unconstitutional (412 U.S. 291 (1973).
B. Application
Relying on the findings presented and the previously decided cases involving similar facts and circumstances, the Supreme Court contended that the medical procedure which Mr. Murphy underwent did not constitute a breach of the Fourth and Fourteenth Amendments. Here, the “crime control model” (Penn State University, n.d.a), “due process model” (Penn State University, n.d.b), and “class justice model” (Barak, Leighton, & Flavin, 2007, pp. 117-118) are supposed to embrace the resolution of the issue brought before the Court. Actually, the “class justice model” has little or no application in this case for no apparent social characteristics such as religion or race were involved in the case.
The “crime control model” and “due process model” may fairly address two matters: “probable cause” and the detectives’ compliance with the suspect’s constitutional rights and freedoms. When searching for the ground to detain Mr. Murphy, the investigation team referred to several arguments illustrating his likely relation to the case. First, the home of his wife was not broken and nothing was robbed. Second, the son of the victim who was present in the building on that day did not possess fingernails being able to inflict those wounds on her neck. Third, Mr. Murphy and his wife had not hit if off for a long time during their marriage. Fourth, Mr. Murphy seemed to have visited his family’s home and then returned to Oregon and provided a lot of information and given testimony to the police without the official request to do this which is suspiciously for ordinary police officers (412 U.S. 291 (1973). In this instance the “crime control model” justifies itself, however, the defendant did not admit his guilt.
Pursuant to the “due process model” principles, law enforcement bodies must respect an individual’s procedural rights spelt out in the Constitution otherwise the court will be obliged to terminate the proceedings and release a suspect due to the inadmissibility of evidence collected. In the given case, the Supreme Court determined that the evidence collected was lawful and thus admissible due to a high likelihood of Murphy’s relation to the murder committed (412 U.S. 291 (1973).
C. Conclusion
The Supreme Court of the United States annulled the judgment of the Court of Appeals and affirmed the defendant’s guilt.
Obiter Dictum
In the opinion of the Court, resting on the judgment in the case of Davis v. Mississippi, if the police detectives could not find “probable cause” to take his “fingernail scrapings”, then this medical procedure would likely have been recognized as unconstitutional.
References
412 U.S. 291 (1973). Retrieved from https://supreme.justia.com/cases/federal/us/412/291/case.html
Barak, G., Leighton, P., & Flavin, J. (2007). Class, race, gender, and crime: The social realities of justice in America. Lanham, MD: Rowman & Littlefield Publishers, Inc.
Penn State University. (n.d.a). The crime control model. Retrieved from http://elearning.la.psu.edu/crim/100/lesson-1/the-crime-control-model
Penn State University. (n.d.b). The due process model. Retrieved from http://elearning.la.psu.edu/crim/100/lesson-1/the-due-process-model
