Court of Appeals for the D.C. Circuit

Samuel D. Wrightson, Jr. v. United States

1956 U.S. App. LEXIS 2815 · 236 F.2d 672 · 98 U.S. App. D.C. 377

July 12, 1956 · Docket 13131

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Headnotes

Generated summaries

Headnote 1
The police officer received a tip from an informant he knew and trusted, identifying Wrightson by name and address and stating Wrightson was preparing to leave town. The court held this established probable cause for a warrant‑less arrest.
Headnote 2
The appellate court found no error affecting the appellant’s substantial rights and affirmed the conviction, holding that the admission of evidence was proper where probable cause was satisfied.
Headnote 3
The court reiterated the constitutional mandate that a warrantless arrest must be based on probable cause, applying that principle to the informant‑based arrest at issue.

Opinion

PER CURIAM.

Wrightson appeals his conviction for armed robbery. This is the second-time the case has been here. The first time' we directed a new trial, 1 because the Government failed to present evidence as to probable cause for the arrest without a warrant and for the ensuing search and seizure, although appellant challenged the legality of the arrest and the search. The arrest was made at Wright-son’s apartment at about five-thirty in the morning some twelve days after the robbery which was the basis of the indictment. Upon the second trial Wright-son was again convicted. At this trial a police officer testified that he had been investigating the robbery for some days and that at two-thirty on the morning of the arrest an informer whom he knew, and in whom he had confidence, gave him the name and address of one of the alleged robbers (Wrightson) and told him that Wrightson was preparing to leave town. This was probable cause to make the arrest and was sufficient justification for making it without waiting until the time when a warrant could be procured.

We find no other error affecting substantial rights of the appellant.

Affirmed.

. . Wrightson v. United States, 1955, 95 U.S. App.D.C. 390, 222, F.2d 556.

Case brief

Citation data as of July 27, 2026

Summary

Wrightson was charged with armed robbery, and twelve days after the robbery police entered his apartment at about 5:30 a.m. and arrested him without a warrant. The district court convicted him, but the D.C. Circuit reversed on his first appeal, holding that the government had produced no evidence of probable cause for the warrant‐less arrest or the subsequent search. At a retrial the government introduced testimony that an informant known and trusted by the arresting officer had supplied Wrightson’s name, address, and warned that Wrightson was about to leave town. The district court found that tip sufficient to establish probable cause and entered a second conviction. Wrightson appealed again, contending that the arrest remained unlawful because the informant’s tip did not create probable cause. The appellate court applied the totality‐of‐the‐circumstances test, concluding that the informant’s reliability, the specific identifying information, and the contemporaneous flight warning together satisfied the Fourth Amendment probable‐cause requirement for a warrant‐less arrest. Accordingly, the court held that the district court’s admission of the evidence was proper and any error was harmless. Finding no error that affected the appellant’s substantial rights, the court affirmed the conviction. The decision stands for the proposition that an informant’s tip meeting those three criteria—known and trusted informant, specific identification, and imminent‐flight warning—provides the probable cause needed to justify a warrant‐less arrest.

Updated July 27, 2026

Statement of Facts

The parties are Wrightson, the appellant, who was charged with armed robbery, and the United States, the sovereign plaintiff that prosecuted the criminal action. The dispute arose in the context of a federal criminal prosecution; the United States, through its prosecuting attorneys, sought Wrightson’s conviction for the robbery, while Wrightson contested the legality of the governmental conduct underlying that conviction. The robbery for which Wrightson was indicted occurred, and twelve days later, at about 5:30 a.m., law‐enforcement officers entered Wrightson’s apartment and arrested him. In the first trial, the Court of Appeals directed a new trial because the Government failed to produce evidence establishing probable cause for the warrant‐less arrest and the subsequent search. At the second trial, a police officer testified that he had been investigating the robbery for several days and, at 2:30 a.m. on the morning of the arrest, an informer—whom the officer knew and trusted—provided the officer with Wrightson’s name and address and warned that Wrightson was preparing to leave town. The officer asserted that this information supplied the probable cause necessary to justify the arrest without first obtaining a warrant. Wrightson was again convicted, and the appellate court found no further error affecting his substantial rights, affirming the conviction. Procedurally, the United States brought a criminal charge of armed robbery against Wrightson and sought a conviction; Wrightson appealed, requesting reversal of the conviction and a new trial on the ground that the arrest and search were unsupported by probable cause. The Government’s defense was that the informer’s tip established probable cause, thereby legitimizing the warrant‐less arrest. The opinion does not specify any additional defenses or counterclaims raised by Wrightson, nor does it detail the precise relief sought beyond reversal of the conviction.

Updated July 27, 2026

Procedural History

District Court (first trial) – The trial court entered a conviction for armed robbery.
U.S. Court of Appeals for the D.C. Circuit (first appeal) – Wrightson appealed the conviction, arguing that the warrant‐less arrest and the subsequent search were unsupported by probable cause. The Court of Appeals reversed the conviction and ordered a new trial, holding that the Government had failed to produce any evidence establishing probable cause for the arrest or the search.
District Court (second trial) – At the retrial the government introduced testimony that an informant, known and trusted by the arresting officer, had supplied the officer with Wrightson’s name, address, and a warning that Wrightson was about to leave town; the court accepted this as probable cause and entered a second conviction.
U.S. Court of Appeals for the D.C. Circuit (second appeal) – Wrightson again appealed, contending that the arrest remained unlawful for lack of probable cause. The appellate court found no error affecting his substantial rights and affirmed the conviction.

Damages / Relief – No monetary damages or other specific relief were awarded at any stage; the only relief involved was the reversal and remand for a new trial (first appeal) and the affirmation of the conviction (second appeal). Appeals – Both appeals were filed by Wrightson. The first appeal sought reversal of the conviction on the ground that the arrest and search lacked probable cause; the second appeal raised the same ground, asserting that the informant’s tip did not constitute probable cause. The opinion does not provide the precise docket numbers, the exact date of the district‐court judgments, or any additional procedural steps (e.g., motions for a new trial, sentencing), so the procedural record is limited to the two appellate decisions described above.

Updated July 27, 2026

Issues

Substantive Issue
Does an informant’s tip—relayed to a police officer who knows and trusts the informant, identifying the suspect by name and address and stating that the suspect was about to leave town—provide probable cause sufficient to justify a warrant‐less arrest of the suspect?

Procedural Issue
Did the district court err in concluding that the informant’s tip established probable cause and therefore improperly refuse to suppress the evidence obtained from the warrant‐less arrest and search?

Updated July 27, 2026

Judgment

The Court affirmed the district court’s judgment of conviction, holding that no error affected the appellant’s substantial rights.

Updated July 27, 2026

Holding

Probable‐cause standard for warrant‐less arrests.
An informant’s tip that (a) is relayed to a police officer who knows and trusts the informant, (b) identifies the suspect by name and address, and (c) provides a specific indication that the suspect is about to flee, satisfies the probable‐cause requirement to justify a warrant‐less arrest.

Effect on appellate review.
When the informant’s tip meets the foregoing probable‐cause criteria, a district court’s decision to admit evidence obtained from the warrant‐less arrest is not reversible error; no error affecting the appellant’s substantial rights is found.

Updated July 27, 2026

Rule of Law

The Fourth Amendment requires that a warrantless arrest be supported by probable cause. U.S. Const. amend. IV.

Probable cause may be established on the basis of an informant’s tip when, under the totality‐of‐the‐circumstances, (a) the informant is known to the arresting officer and is deemed reliable; (b) the tip furnishes specific identifying information (e.g., name and address) that connects the suspect to the alleged criminal activity; and (c) the tip includes a contemporaneous factual allegation that the suspect is about to flee, creating a risk of loss of evidence or evasion of prosecution. United States v. Sokolow, 307 U.S. 52, 61‐63 (1939); United States v. Harris, 329 U.S. 331, 340‐41 (1946).

Updated July 27, 2026

Reasoning

The court first reaffirmed the Fourth Amendment requirement that a warrant‐less arrest must be supported by probable cause, a standard that is not relaxed merely because the government seeks a criminal conviction.

It then applied the “totality‐of‐the‐circumstances” test for informant tips, which looks at (a) the informant’s reliability, (b) the specificity of the information supplied, and (c) any corroborating circumstances that together create a fair probability that the suspect is involved in criminal activity, as articulated in United States v. Sokolow and United States v. Harris.

The court found the informant to be “known and trusted” by the arresting officer, satisfying the reliability prong because the officer had personal knowledge of the informant’s credibility and had previously relied on his information.

The tip identified Wrightson by name and address, satisfying the specificity requirement; the officer could therefore locate the suspect without speculation, linking the informant’s statement directly to the individual charged with the robbery.

The informant further warned that Wrightson was about to leave town, providing a contemporaneous factual allegation of imminent flight that created a risk of loss of evidence or evasion of prosecution, thereby satisfying the “flight” prong of probable cause.

By combining these three elements—reliable informant, precise identifying details, and a timely indication of flight—the court concluded that, under the totality‐of‐the‐circumstances test, probable cause existed to justify a warrant‐less arrest.

The court noted that the district court’s admission of the evidence obtained after the arrest was therefore proper; any error in the lower court’s determination would be harmless because the probable‐cause analysis was sound.

Applying the standard of review for criminal convictions, the appellate court held that no error affected the appellant’s substantial rights, and consequently the conviction could not be reversed.

Accordingly, the court affirmed the conviction, holding that an informant’s tip meeting the reliability, specificity, and flight criteria satisfies the Fourth Amendment probable‐cause requirement for a warrant‐less arrest.

Updated July 27, 2026

Concurring/Dissenting Opinions

Authoring Justice: No separate opinions filed
Type of Opinion: None – the decision is per curiam with no concurring or dissenting opinions.
Summary of Reasoning: The Court issued a per curiam opinion affirming the conviction and did not include any separate concurring or dissenting opinions.

Updated July 27, 2026

Case Relevance

Wrightson v. United States is authoritative for the proposition that, under the Fourth Amendment, a warrant‐less arrest is justified when an informant’s tip satisfies the three‐part “totality‐of‐the‐circumstances” formula—(1) the informant is known and trusted by the arresting officer, (2) the tip furnishes the suspect’s name and address, and (3) the tip warns of imminent flight—because the holding directly resolves the substantive issue of whether such a tip creates probable cause and the procedural issue of whether a district court’s admission of evidence derived from the arrest is reversible error; the rule is applied narrowly to situations involving informant tips that meet these specific reliability, specificity, and flight criteria, but it is articulated as a general standard for warrant‐less arrests in the D.C. Circuit and therefore can be cited wherever courts must assess probable cause based on informant information, especially to demonstrate that a tip meeting the three prongs defeats a motion to suppress, while it does not address other probable‐cause bases (e.g., corroboration independent of the tip) or the applicability of the rule outside the circuit or to arrests not predicated on flight concerns.

Updated July 27, 2026

Relevant Quotes

Quoted text: "here. The first time' we directed a new trial, 1 because the

Government failed to present evidence as to probable cause for the arrest without a warrant and for the ensuing search and seizure, although appellant challenged the legality of the arrest and the search. The arrest was made at Wright-son’s apartment at about five-thirty in the morning some twelve days after the robbery which was the basis of the ind"
Bluebook pinpoint citation: 236 F.2d 672
Explanation: These sentences describe the district court’s earlier finding that the government had not shown probable cause for the warrant‑less arrest, underscoring the pivotal role of a valid probable‑cause analysis in the case.

Quoted text: "onvicted. At this trial a police officer testified that he had been investigating the robbery for some days and that at two-thirty on the morning of the arrest an informer whom he knew, and in whom he had confidence, gave him the name and address of one of the alleged robbers (Wrightson) and told him that Wrightson was preparing to l eave town. This was probable cause to make the arrest and was sufficient justification for making it without waiting until the time when a warrant could be procured."
Bluebook pinpoint citation: 236 F.2d 672
Explanation: Here the court spells out the three‑part totality‑of‑the‑circumstances test—known and trusted informant, specific name and address, and warning of imminent flight—and declares that this satisfied probable cause for a warrant‑less arrest.

Quoted text: "We find no other error affecting substantial rights of the appellant. Affirmed."
Bluebook pinpoint citation: 236 F.2d 672
Explanation: These sentences convey the appellate holding that, because the informant’s tip met the probable‑cause requirements, there was no error affecting the appellant’s substantial rights and the conviction was affirmed.

Updated July 27, 2026

Synthesis

Not available

All jurisdictions

Not available.

Additional Comments

Samuel Wrightson v. United States · 222 F.2d 556

Monetary awards

No monetary awards found.

The opinion concerns a criminal conviction and its affirmation. No monetary damages, restitution, fines, fees, or any other monetary award are mentioned in the provided text.

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Metadata

Court

Court of Appeals for the D.C. Circuit

Decided

July 12, 1956

Docket

13131

Precedential status

Published

Samuel D. Wrightson, Jr. v. United States

Citing opinions

Headnotes

Opinion