CA3: Mistaken stop not unconstitutional when defendant provides false ID
FourthAmendment.com:
Officers were looking for a parole violator, and they had information from a CI that he was driving a particular car. That information proved to be wrong, but the person stopped gave a false ID when he was stopped. The stop would not be suppressed because, although mistaken, it was not unconstitutional [not to mention the independent crime of providing the false ID]. United States v. Jaison, 2008 U.S. App. LEXIS 15558 (3d Cir. July 22, 2008) (unpublished):
“When the police have probable cause to arrest one party, and when they reasonably mistake a second party for the first party, then the arrest of the second party is a valid arrest.” Hill v. California, 401 U.S. 797, 802 (1971). The reasonableness of the mistaken arrest of another party is “determined by considering the totality of the circumstances surrounding the arrest.” United States v. Glover, 725 F.2d 120, 122 (D.C. Cir. 1984). The District Court found that Wehrle obtained information, from confidential informants, that the individual sought operated the vehicle in which Thompson was arrested, that these informants had provided reliable information in the past, and that Thompson’s physical appearance was sufficiently similar to the individual on the “wanted” poster. The District Court has not clearly erred with respect to these underlying factual determinations, and we hold that Wehrle’s initial detention of Thompson was reasonable under the totality of the circumstances.
Thompson next argues that the officers were obligated to release him once they suspected that he was not the individual sought, and that the evidence seized should therefore be suppressed as the fruit of an unlawful detention. The Supreme Court has stated that when an “officer has probable cause to believe that an individual has committed even a very minor criminal offense in his presence, he may, without violating the Fourth…