Atwater v. Lago Vista
How much action can a police officer take against someone accused of violating a law that is punishable only by a fine, rather than jail time, during a traffic stop? That's the question the Supreme Court tackled in its 2001 Atwater v. Lago Vista ruling. The case, which involved a mother arrested for violation of Texas's seat belt laws, would give rise to a ruling with far reaching consequences for misdemeanor defendants throughout the United States.
Seatbelt Laws in Texas
The seat belt law that Atwater ran afoul of required front seat passengers and children to be buckled into any moving vehicle with a seat belt. This law, if broken, would result in a fine of up to $50 per offense. The seat belt laws in Texas did not require anyone to be arrested or taken into custody as a response to violations. Officers had the ability to simply issue a citation, the same way that they would for a number of other minor traffic violations. However, the law did explicitly give them the right to arrest anyone found to be in violation of the law at their discretion.
Atwater was pulled over for violating the seat belt law in 1997. At the time, she was driving a pickup truck, and her two young children were seated next to her in the front seat. The children were not wearing their seat belts, which a police officer noticed. He pulled her over and yelled to her that she was going to jail. When he asked for her license and registration, and Atwater said her purse had recently been stolen, the officer continued to berate her, saying he'd “heard that story two-hundred times.”
Atwater was taken to jail and booked until she was released on a $310 bond—all for a violation that resulted in a no contest plea to the seatbelt charges and a $50 fine. Atwater sued the city for holding her in violation of her Fourth Amendment protections against unreasonable search and seizure.
Supreme Court Ruling
In a sharply divided 5-4 ruling, the Supreme Court of the United States ruled in Atwater v. Lago Vista that there was no reason that police should not be allowed to arrest somebody and book them simply because the crime they had committed could not result in actual jail time. The Court pointed out that many jurisdictions allowed such arrests, and that the common law of the United States seemed to indicate that such arrests were generally well tolerated by members of the community.
The Court did, however, note that these arrests may be considered negative, and that states may prefer to enact legislation that stops arrests for misdemeanors punishable only with fines. However, the justices preferred to leave this option up to legislatures rather than enforcing it through judicial fiat.
In a strongly worded dissent, Justice O'Connor wrote in Atwater v. Lago Vista that Atwater's arrest had been a direct violation of her Fourth Amendment rights. The arrest and booking was, O'Connor said, the “quintessential seizure” and was an unnecessary indignity to Atwater.