Sanders v. U.S

In Sanders v. U.S., 339 A.2d 373 (D.C. 1975), there was an outstanding arrest warrant for a man named Saunders. The police encountered Sanders, who gave them an identification card that misspelled his name as Saunders. Sanders matched the description of the subject of the warrant and in answer to questions gave the police information connecting him to the jurisdiction where the warrant was issued. The police arrested Sanders pursuant to the warrant and in a search incident to the arrest recovered illegal weapons. In fact, the warrant was for Saunders, another person. In a prosecution against him for illegal weapons possession, Sanders sought, unsuccessfully, to suppress the weapons as having been obtained in a search incident to an invalid arrest. On appeal after conviction, the District of Columbia Court of Appeals, applying Hill, held that a mistaken arrest of a person who is not the subject of the arrest warrant pursuant to which he was arrested is valid when the arresting officers reasonably believe in good faith that the person arrested is the subject of the warrant. The Court explained: Should doubt as to the correct identity of the subject of the warrant arise, the arresting officer obviously should make immediate reasonable efforts to confirm or deny the applicability of the warrant to the detained individual. If, after such reasonable efforts, the officer reasonably and in good faith believes that the suspect is the one against whom the warrant is outstanding, a search pursuant to the arrest of that person in not in contravention of the Fourth Amendment. (339 A.2d at 379.)