Director General of Railroads v. Kastenbaum Case Brief

Director General of Railroads v. Kastenbaum, 263 U.S. 25, 44 S.Ct. 52 (1923)

FACTS: 21 tubs of butter were stolen from a rail car in Buffalo, New York. Later that night, a trolley car collided with a horse and wagon, and the stolen tubs were recovered from the wagon. The two men in the wagon fled.

The railroad detective believed they had traced the ownership of the horse to Kastenbaum, a huckster. The detective notified the local police, who detailed two officers to accompany him to Kastenbaum house, where Kastenbaum was arrested without a warrant. After a lengthy process, the magistrate dismissed the case against Kastenbaum.

Kastenbaum horse “proved to be one of another color.”

Kastenbaum sued the railroad detective for false arrest.

ISSUE: Did the officers’ good faith belief in Kastenbaum guilt constitute probable cause to arrest Kastenbaum without a warrant?

HOLDING: No

DISCUSSION: The Court concluded that “the question is not whether he (the arresting officer) thought the facts sufficient to constitute probable cause, but whether the court thinks they did.” The Court went on to state that “[p]robable cause is a mixed question of law and fact.” The Court concluded that good faith “must be grounded on facts within knowledge of the (officer), which in the judgment of the court would make his faith reasonable.”