United States v. Morris

What This Case Is About

United States v. Morris is a federal criminal case from the Fifth Circuit addressing two important constitutional questions: whether evidence seized during an arrest was the product of an unlawful arrest (a Fourth Amendment challenge), and whether a firearms registration requirement violated the Fifth Amendment privilege against self-incrimination. While not a § 1983 case, Morris addresses the legality of search incident to arrest—a doctrine that frequently arises in civil rights cases challenging the scope of police searches.

The Facts

John England Morris was found in possession of a fully automatic rifle that had not been registered to him in the National Firearms Registration and Transfer Record, in violation of 26 U.S.C. §§ 5861(d) and 5871. The weapon was seized by law enforcement during or incident to his arrest.

Morris challenged his conviction on two grounds. First, he argued that the evidence—the automatic rifle—should have been suppressed because it was seized incident to an unlawful arrest. He contended that the officers lacked probable cause or legal authority to arrest him, and that therefore anything found during the arrest was fruit of the poisonous tree.

Second, Morris argued that as applied to him, the registration provisions of the National Firearms Act violated his constitutional privilege against compulsory self-incrimination. His argument was that requiring him to register a firearm he possessed illegally would effectively force him to incriminate himself.

What the Court Decided

The Fifth Circuit found both of Morris’s claims to be without merit and affirmed the conviction.

On the Fourth Amendment issue, the court held that the arrest was lawful and that the seizure of the automatic rifle was a valid search incident to arrest. The court found that the officers had sufficient legal authority to make the arrest and that the weapon was properly seized during that process.

On the Fifth Amendment issue, the court rejected Morris’s self-incrimination argument. The court found that the registration requirements of the National Firearms Act had been amended after the Supreme Court’s decision in Haynes v. United States (1968) to remove the self-incrimination problem. Under the amended statute, registration information could not be used against the registrant in a criminal prosecution, eliminating the compelled self-incrimination concern.

Why This Case Matters for Your § 1983 Case

Search incident to arrest has defined boundaries. The scope of what officers can search during a lawful arrest is a recurring issue in § 1983 excessive force and unlawful search cases. If the underlying arrest is lawful, items found on the person or in the immediate area are generally admissible.

Challenging the arrest itself is key. Morris illustrates that the legality of a search often depends on the legality of the underlying arrest. If you can show the arrest was unlawful (no probable cause), the evidence seized during the arrest may be suppressible—and the arrest itself may support a § 1983 false arrest claim.

Fifth Amendment protections have limits. The privilege against self-incrimination does not automatically prevent the government from requiring registration or disclosure if statutory protections eliminate the risk of criminal use of the information.

Key Takeaway

United States v. Morris confirms that evidence seized incident to a lawful arrest is constitutionally permissible and that the legality of the arrest is the threshold question. For § 1983 plaintiffs, the case underscores that challenging an allegedly unlawful search typically requires first establishing that the underlying arrest lacked probable cause.