context: Even though the offense said to be the basis for Reid's arrest - "disorderly gambling" - is not a crime, that probable cause existed to arrest him for any crime is sufficient to render the arrest lawful.
citation_a.signal: see
citation_a.identifier: 277 F.3d 558, 564
citation_a.parenthetical: "an arrest will be upheld if probable cause exists to support arrest for an offense that is not denominated as the reason for the arrest by the arresting officer"
citation_a.sentence: See United States v. Bookhardt, 277 F.3d 558, 564 (D.C.Cir.2002) (“an arrest will be upheld if probable cause exists to support arrest for an offense that is not denominated as the reason for the arrest by the arresting officer”); Bell v. United States, 254 F.2d 82, 86 (D.C.Cir.1958) (“The question is not what name the officer attached to his action; it is whether, in the situation in which he found himself, he had reasonable ground to believe a felony had been committed”); see also Whren v. United States, 517 U.S. 806, 813, 116 S.Ct. 1769, 135 L.Ed.2d 89 (1996) (“Subjective intentions play no role in ordinary, probable-cause Fourth Amendment analysis”); United States v. Wesley, 293 F.3d 541, 545 (D.C.Cir.2002) (probable cause when “facts and circumstances within the officer’s knowledge ... are sufficient to warrant a prudent person in believing that the suspect has committed, is committing, or is about to commit an offense”). Because the search about which Reid complains was incident to a lawful arrest, it was reasonable under the Fourth Amendment, see Chimel v. California, 395 U.S. 752, 763, 89 S.Ct. 2034, 23 L.Ed.2d 685 (1969), irrespective of the arresting officers’ mistaken belief that “disorderly gambling” is a crime in the District of Columbia.
citation_b.signal: see also
citation_b.parenthetical: "Subjective intentions play no role in ordinary, probable-cause Fourth Amendment analysis"
citation_b.sentence: See United States v. Bookhardt, 277 F.3d 558, 564 (D.C.Cir.2002) (“an arrest will be upheld if probable cause exists to support arrest for an offense that is not denominated as the reason for the arrest by the arresting officer”); Bell v. United States, 254 F.2d 82, 86 (D.C.Cir.1958) (“The question is not what name the officer attached to his action; it is whether, in the situation in which he found himself, he had reasonable ground to believe a felony had been committed”); see also Whren v. United States, 517 U.S. 806, 813, 116 S.Ct. 1769, 135 L.Ed.2d 89 (1996) (“Subjective intentions play no role in ordinary, probable-cause Fourth Amendment analysis”); United States v. Wesley, 293 F.3d 541, 545 (D.C.Cir.2002) (probable cause when “facts and circumstances within the officer’s knowledge ... are sufficient to warrant a prudent person in believing that the suspect has committed, is committing, or is about to commit an offense”). Because the search about which Reid complains was incident to a lawful arrest, it was reasonable under the Fourth Amendment, see Chimel v. California, 395 U.S. 752, 763, 89 S.Ct. 2034, 23 L.Ed.2d 685 (1969), irrespective of the arresting officers’ mistaken belief that “disorderly gambling” is a crime in the District of Columbia.