Quick Summary
In two separate cases, the legality of New York statutes permitting the entry of police into a private residence without a warrant was challenged. In both instances, the defendants sought to suppress unwarranted evidence. The New York Court of Appeals upheld both convictions in a single decision, citing the regularity of warrantless arrests and search & seizure.
The issue before the court was whether an unwarranted search and seizure is a violation of the fourth amendment or not.
The U.S. Supreme Court decided that police cannot forcibly enter a suspect’s home to arrest without a warrant, except in certain circumstances. The Fourth Amendment prohibits warrantless home searches during arrests. Even with probable cause or legislative authorization, searches are illegal except in “exigent circumstances.”
Rule of Law
The Fourth Amendment of the United States Constitution prohibits warrantless searches of private residences except in “exigent circumstances.” Assuming there is probable evidence linking the seized property to criminal activity.
The seizure of such property in plain view is presumed to be legal and does not constitute an invasion of privacy.
Facts of the Case
In two separate cases, the legality of New York statutes permitting the entry of police into a private residence without a warrant and the use of force, if necessary, to execute a routine criminal arrest was challenged.
In the first case, the police had probable cause to suspect Payton (defendant) of murder. Without a warrant, the police arrived at his residence at 7:30 a.m. to make an arrest. When no one answered the door, the police forcibly entered Payton’s home thinking he was there (he was not). A gun shell casing was discovered in plain view, which was admitted as evidence at his trial.
In a similar case, officers arrested Mr. Riddick. Again, officers searched his home without a warrant and discovered drugs near where he was taken into custody.
In both instances, the defendants sought to suppress unwarranted evidence. The New York trial judge ruled that warrantless entry was permissible under state law and declined to suppress evidence obtained without a warrant. The New York Court of Appeals upheld both convictions in a single decision, citing the regularity of warrantless arrests and search & seizure.
Issue
Isn’t this a violation of the Fourth Amendment, If police search a home without a warrant when they have probable cause but not “exigent circumstances”?
Holding and Conclusion
Yes, it's a violation of the Fourth Amendment.
Supreme Court reversed lower court rulings and remanded the cases. Citing the Fourth and Fourteenth Amendments, justices said police could not forcefully enter a suspect’s home to arrest without a warrant.
The Fourth Amendment prohibits warrantless home searches during arrests. Even with probable cause or legislative authorization, searches are illegal except during “exigent circumstances.”
Reasoning and Analysis
As a means of distinguishing the present case from Watson, which upheld the legality of a warrantless arrest in a public place, both the majority and concurring opinions of the Supreme Court emphasized the importance of maintaining one’s home’s privacy.
When there is a high likelihood that a suspect will flee or when there is an imminent threat to human life, the Supreme Court will permit an arrest. However, according to the dissidents, the term “exigent circumstances” is too broad and will lead to additional litigations.
Relevant FAQs of this case
What is the Payton Doctrine?
Without suspect permission and a valid arrest warrant, it is unconstitutional to enter a suspect’s home to search for evidence or to arrest them. The only exception is during an exigent circumstance.
What do exigent circumstances mean?
Any situation that would make a reasonable person think that entry (or other quick action) is needed to keep officers or other people from getting hurt, important evidence from being destroyed, the suspect from getting away, or something else that would unfairly hurt law enforcement efforts.
The most common exigent circumstances are as follows, and each condition has its own set of rigorous restrictions:
- Emergency Help: The police can go into a building without a warrant if they have a good reason to think someone inside needs immediate medical help. A good example is If they hear gunfire inside a building and think people might be hurt, they might go inside to help those in need.
- Destruction of Evidence: When the police have reason to believe that waiting for a warrant will cause evidence of a crime to be destroyed, they can enter a building without a warrant. For example, the police have set up a perimeter around a house where they think drug dealers are hiding. The police then know that the fire was started to remove the evidence. Because of this, police would be permitted to enter without a warrant, preventing potentially crucial evidence from being destroyed.
References
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