Peaches Wild Party Made Its Way to The Supreme Court
On March 16, 2008, Metropolitan Police Department officers responded to a noise complaint for a house party. Upon arrival, the officers heard loud music coming from the house. The officers then entered the house and observed party guests, including Theodore Wesby, drinking and watching “scantily clad women with money tucked into garter belts.” The partygoers claimed that a woman called “Peaches” was the host of the party, and that she had received permission from the owner, from whom Peaches was leasing the house. Peaches was not present but confirmed that she had permission from the owner, but when an officer called the owner, the owner claimed that Peaches did not lease the property and that he had not given permission for the party. The partygoers were then arrested.
Sixteen of the arrested partygoers sued the officers and the District of Columbia for false arrest. The district court ruled in favor of the partygoers. The U.S. Court of Appeals for the D.C. Circuit affirmed and held both that the officers did not have probable cause for entry. Probable cause to arrest for unlawful entry under D.C. law exists where a reasonable officer concludes from information known at the time that the arrestee knew or should have known that they entered the house against the will of the owner. The lower court reasoned that, because the partygoers believed in good faith that the owner had given Peaches permission for the party, they could not have intended to enter unlawfully.
The Supreme Court disagreed and held that there was probable cause to arrest the partygoers. Considering the “totality of the circumstances,” Maryland v. Pringle, 540 U. S. 366, 371, the officers made an “entirely reasonable inference” that the partygoers knew they did not have permission to be in the house. Taken together, the condition of the house and the conduct of the partygoers allowed the officers to make several “‘common-sense conclusions about human behavior.’” Illinois v. Gates, 462 U. S. 213. Because most homeowners do not live in such conditions or permit such tawdry activities in their homes, the officers could infer that the partygoers knew the party was not authorized.
The officers also could infer that the partygoers knew that they were not supposed to be in the house because they scattered and hid when the officers arrived. See Illinois v. Wardlow, 528 U. S. 119. The partygoers’ vague and implausible answers to questioning also gave the officers reason to infer that the partygoers were lying and that their lies suggested a guilty mind. Peaches’ lying and evasive behavior gave the officers reason to discredit everything she said. The officers also could have inferred that she lied when she said she had invited the partygoers to the house, or that she told the partygoers that she was not actually renting the house.
The Supreme Court also held that the lower court failed to follow two basic and well established principles of law. First, it viewed each fact “in isolation, rather than as a factor in the totality of the circumstances.” Pringle. Second, it believed that it could dismiss outright any circumstances that were “susceptible of innocent explanation,” United States v. Arvizu, 534 U. S. 266, 277. Instead, it should have asked whether a reasonable officer could conclude—considering all of the surrounding circumstances, including the plausibility of the explanation itself—that there was a “substantial chance of criminal activity,” Gates, supra, at 244, n. 13.