Florida v. Royer Case Brief Summary | Law Case Explained

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Florida v. Royer | 460 U.S. 491 (1983)

Police officers can conduct a brief Terry stop when they suspect misbehavior. But what exactly can they do during the stop? The United States Supreme Court considered that question in Florida versus Royer.

Detectives at Miami International Airport watched Mark Royer buy a one-way ticket to New York. Royer’s behavior and appearance fit a drug courier profile, so the detectives approached Royer and asked to speak to him.

The officers requested Royer’s airline ticket and driver’s license, which Royer produced. The ticket and luggage tags bore the name Holt, but his driver’s license bore his correct name, Royer. The detectives then informed Royer that they were narcotics investigators and suspected that Royer was carrying drugs.

The officers kept Royer’s ticket and license and asked Royer to accompany them to a small room about forty feet away. Without verbally consenting, Royer went with them. The room turned out to be an interrogation room. The detectives retrieved Royer’s baggage from the airline, also without Royer’s consent. They asked Royer’s consent to search his luggage. Again, without saying anything, Royer unlocked one suitcase using a key. One of the detectives opened it without asking Royer’s consent and found marijuana. Royer said that he didn’t know the combination to the second suitcase but consented to the detectives’ breaking into it. The second suitcase contained more marijuana. The detectives then arrested Royer. About fifteen minutes had elapsed from the officers’ initial approach until Royer’s arrest.

Royer was tried in state court for felony drug possession. The detectives admitted that they didn’t have probable cause to arrest Royer until the drugs were revealed. But the trial court admitted the drugs, holding that Royer had consented to the search of his luggage. The court of appeals panel affirmed, but the en banc Florida District Court of Appeal reversed, holding that Royer had been involuntarily confined without probable cause and that the detention exceeded the bounds of a Terry stop. The United States Supreme Court granted Florida’s cert petition.

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