Devenpeck v. Alford

The Court rejected outright a “closely related offense” rule, which would have permitted the officer to establish probable cause for offense (or a closely related offense) for which the defendant was arrested alone. No other potential offenses could sustain the arrest, even if the officer could establish probable cause. The Supreme Court has previously established that the determination of probable cause depends upon the facts known to the arresting officer at the time of the arrest. Maryland v. Pringle. The officer’s subjective motive for making the arrest is irrelevant. The Court stated the “[S]ubjective intent of the arresting officer, however it is determined (and of course subjective intent is always determined by objective means), is simply no basis for invalidating an arrest.”