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Probable cause before arrest

Michael Leroy Waite v. Florida

Updated Nov 12, 2026

In brief

Where it stands
Dismissed

Petition denied.

What it’s about
Michael Waite challenged whether Florida’s process for issuing an arrest order met the Fourth Amendment’s requirement that a neutral official independently decide there was enough evidence to arrest him.
Who it affects
Waite did not get Supreme Court review, and the Court did not decide whether Florida’s process met the Fourth Amendment.

Summary: written with AI from the case record.

Illustration for Michael Leroy Waite, Petitioner v. Florida
Conceptual illustration · AI-generated

What it's about

The Supreme Court refused to hear his case (denied his petition for review), so it did not decide that question.

A capias is an arrest order; Waite’s challenge concerned whether a neutral official independently approved it based on enough evidence for an arrest.

Question presented

Whether the capias procedure used to order Waite from the curtilage of his home and arrest him satisfied the Fourth Amendment’s requirement for a neutral and detached official to independently determine probable cause?

Documents

1

Docket activity

6
  • New analysis added

    Nov 12, 2026 · Court records

  • AI analysis generated: Case Briefing

    Nov 12, 2026 · Generated

  • AI analysis generated: Decision Record

    Nov 12, 2026 · Generated

  • Case data updated: summary, question_presented, generation_metadata

    Nov 12, 2026 · Court records

  • Case data updated: question_presented, extraction_metadata

    Nov 12, 2026 · Court records

Show 1 more
  • Brief added: Petition

    Sep 24, 2026 · Court records

Sources

Primary materials plus reporting. Best-effort analysis: this explainer relies on a mix of primary materials and trusted secondary sources. Official filings and opinions remain authoritative.

Checked Nov 12, 2026Methodology

Court records and filings

Reporting and analysis