Devenpeck v. Alford, 543 U.S. 146 (2004), was a United States Supreme Court decision dealing with warrantless arrests and the Fourth Amendment.

[1] On the night of November 22, 1997, Jerome Alford was driving on Washington State Route 16 when he stopped to assist a stranded vehicle.

Believing that the recording was illegal, Devenpeck arrested Alford, citing the Washington Privacy Act.

Alford then brought a civil suit against Devenpeck under §1983, claiming his arrest violated the Fourth Amendment.

Taping an officer during a traffic stop was legal, and while there may have been probable cause to arrest Alford for other offenses, including impersonating a police officer or obstructing a public servant, the Court of Appeals ruled that these offenses were not "closely related" to the tape recording, which was Devenpeck's sole stated reason for arresting Alford.