In re T.L.

Summary

The District of Columbia Court of Appeals held that a juvenile's loud but peaceful protests and calls for help after an officer unlawfully seized his money did not constitute or threaten a breach of the peace under D.C. Code § 22-1321. The court concluded that the officer lacked probable cause to arrest the juvenile for disorderly conduct, and that the cocaine discovered in the search incident to that arrest was inadmissible. The court reversed the juvenile delinquency adjudications and directed entry of an acquittal on the disorderly conduct charge.

Holdings

1. T.L.'s loud but peaceful protestations and calls for his mother's help, made in response to the officer's unjustified seizure of his money, were reasonable under the circumstances and did not amount to or threaten to occasion a breach of the peace or manifest an intent to provoke one under D.C. Code § 22-1321.
2. Officer Elliott lacked probable cause to arrest T.L. for disorderly conduct because T.L.'s conduct did not constitute or threaten to occasion a breach of the peace.
3. The cocaine discovered in the search incident to T.L.'s unlawful arrest had to be suppressed; an officer's reasonable mistake of law cannot supply the probable cause required for an arrest or create a good-faith exception to the exclusionary rule.
4. The evidence was insufficient to prove disorderly conduct, and T.L. was entitled to acquittal on that charge.

Questions Presented

1. Whether T.L.'s loud protestations and calls for his mother, made at night after an officer unjustifiably seized his money, constituted or threatened to occasion a breach of the peace under D.C. Code § 22-1321(3).
2. Whether the police had probable cause to arrest T.L. for disorderly conduct.
3. Whether cocaine discovered in a search incident to T.L.'s unlawful arrest had to be suppressed despite the officer's assertedly reasonable mistake of law.
4. Whether the evidence was sufficient to support T.L.'s disorderly conduct adjudication.

Disposition

reversed_and_remanded