Summary of Ornelas v. United States (1996)

Procedure: Petitioners each pled guilty to possession of cocaine with intent to distribute.  They reserved their right to appeal the District Court’s denial of their motion to suppress the cocaine found in their car, alleging that the police officers violated their Fourth Amendment rights when the officers detained them in the parking lot and when Deputy Luedke searched inside without a warrant.  The District Court had found reasonable suspicion to stop and question petitioners as they entered their car, and probable cause to remove one of their interior panels where a package containing two kilograms of cocaine was found.  After conducting an evidentiary hearing, the Magistrate Judge concluded that the circumstances gave the officers’ reasonable suspicion, but not probable cause.  The Magistrate nonetheless recommended that the District Court deny the suppression motions because he thought, given the presence of a drug-sniffing dog, that the officers would have found the cocaine by lawful means eventually and therefore the drugs were admissible under the inevitable discovery doctrine.  The District Court adopted the Magistrate’s recommendation with respect to reasonable suspicion, but not its reasoning as to probable cause.  The Court of Appeals affirmed the reasonable-suspicion analysis, but remanded the case based on the probable-cause finding.  On remand, the Magistrate Judge found the probable-cause testimony credible.  The District Court accepted the finding, and once again ruled that probable cause supported the search.  Certiorari was granted by the United States Supreme Court to resolve the conflict among the Circuits over the applicable standard of appellate review.

Facts: In the early morning of a December day in 1992, Detective Michael Pautz, who specialized in drug enforcement, was conducting drug-interdiction surveillance in downtown Milwaukee.  Pautz noticed a 1981 two-door Oldsmobile with California plates in a motel parking lot.  The car attracted the detective’s attention for two reasons: because older model, two-door General Motors cars are a favorite with drug couriers because it is easy to hide things in them; and because California is a “source state” for drugs.  Detective Pautz inquired the dispatcher about the car’s registration.  Detective Pautz checked the motel registry and found that an Ismael Ornelas accompanied by another man registered at 4:00 a.m., without reservations.  The last name matched the one given by dispatch, although the first did not.  Pautz called his partner, Donald Hurrle, who had worked in drug enforcement unit for the past 6 years.  The officers contacted the local DEA and asked them to run the names of Miguel Ledesma Ornelas (name given by dispatch), and Ismael Ornelas through the Narcotics and Dangerous Drugs Information System (NADDIS), a federal database of known and suspected drug traffickers.  The NADDIS report identified Miguel Ledesma Ornelas as a heroin dealer from El Centro, California, and Ismael Ornelas, Jr. as a cocaine dealer from Tucson, Arizona.  The officers then summoned Deputy Luedke and the department’s drug-sniffing dog, Merlin.  Sometime later, petitioners emerged from the motel and got into the Oldsmobile.  Detective Hurrle approached the car and identified himself as a police officer, and asked whether they had any illegal drugs.  Petitioners said “No.”  Hurrle then asked for identification and was given two California driver’s licenses bearing the names Saul Ornelas and Ismael Ornelas.  Hurrle asked them if he could search the car and the petitioners consented.  Luedke subsequently discovered two kilograms of cocaine in a panel above the right rear passenger armrest.  The petitioners were arrested.

Legal Issue: Should questions of reasonable suspicion and probable cause to make a warrantless search be reviewed de novo?

Holding: Yes.

Reasoning: (Rhenquist, C.J.) Articulating precisely what “reasonable suspicion” and “probable cause” mean is not possible.  They are commonsense, nontechnical conceptions that deal with “‘the factual and practical considerations of everyday life on which reasonable and prudent men, not technicians, act.'”  Illinois v. Gates, 462 U.S. 213, 231 (1983) (quoting Brinegar v. United States, 338 U.S. 160, 175 (1949)).  The principle components of a determination of reasonable suspicion or probable cause will be events which occurred leading up to the stop or search, and then the decision whether these historical facts, viewed from the standpoint of an objectively reasonable police officer, amount to reasonable suspicion or to probable cause.  Finally, de novo review tends to unify precedent and will come closer to providing law enforcement officers with a defined “‘set of rules which, in most instances, makes it possible to reach a correct determination beforehand as to whether an invasion of privacy is justified in the interest of law enforcement.'”  New York v. Belton, 453 U.S. 454, 458 (1981).  Our cases have recognized that a police officer may draw inferences based on his own experience in deciding whether probable cause exists.  An appeals court should give due weight to a trial court’s finding that the officer was credible and the inference was reasonable.  We therefore hold that as a general matter determinations of reasonable suspicion and probable cause should be reviewed de novo on appeal.  We vacate the judgements and remand the case to the Court of Appeals to review de novo the District Court’s determinations that the officer had reasonable suspicion and probable cause in this case.