Defendant was convicted before the United States District Court for the Central District of California, of possessing stolen mail, and he appealed. The Court of Appeals for the Ninth Circuit, 504 F.2d 849, reversed, holding that defendant's arrest was unconstitutional because postal inspector failed to secure arrest warrant though he had time to do so and that defendant's consent to automobile search was coerced and thus invalid, and the Supreme Court granted certiorari. The Supreme Court, Mr. Justice White, held that where, based on information from reliable informant that defendant possessed stolen credit cards, there was probable cause for arrest, warrantless arrest of defendant by postal officers in restaurant at midday was valid under statute authorizing postal officers to make warrantless arrests for felonies if they have reasonable grounds to believe that felony has been or is being committed, and that defendant, who while on public street subsequent to such arrest, after being given Miranda warnings and further cautioned that results of search of automobile could be used against him, persisted in consenting to search of automobile, gave voluntary and valid consent to search of his automobile.
United States v. Watson, 423 U.S. 411 (1976)
Holding: Government agents may make warrantless arrests of citizens as long as they have probable cause to believe that they have just committed a felony.
