Summary
The Supreme Court held that the Fourth Amendment prohibits police from making a warrantless and nonconsensual entry into a suspect's home to effect a routine felony arrest, absent exigent circumstances. The Court reversed the New York Court of Appeals and held that an arrest warrant based on probable cause generally carries limited authority to enter the suspect's dwelling when there is reason to believe the suspect is inside.
Topics
Practice areas
Questions Presented
- Whether the Fourth Amendment permits police to make a warrantless, nonconsensual entry into a suspect's home to effect a routine felony arrest when there are no exigent circumstances.
- Whether an arrest warrant founded on probable cause authorizes police to enter the suspect's dwelling when there is reason to believe the suspect is inside.
Holdings
- Absent exigent circumstances or consent, the Fourth Amendment prohibits police from making a warrantless and nonconsensual entry into a suspect's home to make a routine felony arrest.
- An arrest warrant founded on probable cause implicitly carries limited authority for police to enter the dwelling in which the suspect lives when there is reason to believe the suspect is within.
Key quotations
“We now reverse the New York Court of Appeals and hold that the Fourth Amendment to the United States Constitution, made applicable to the States by the Fourteenth Amendment, Mapp v. Ohio, 367 U.S. 643; Wolf v. Colorado, 338 U.S. 25, prohibits the police from making a warrantless and nonconsensual entry into a suspect's home in order to make a routine felony arrest.” (445 U.S. at 576)
“Absent exigent circumstances, that threshold may not reasonably be crossed without a warrant.” (445 U.S. at 590)
“Thus, for Fourth Amendment purposes, an arrest warrant founded on probable cause implicitly carries with it the limited authority to enter a dwelling in which the suspect lives when there is reason to believe the suspect is within.” (445 U.S. at 602-603)
Factual background
New York detectives had probable cause to believe Theodore Payton had committed murder, but entered his Bronx apartment without an arrest warrant after receiving no response to their knock and forced the door open. Payton was absent, and officers seized a shell casing in plain view. In a separate case, police entered Obie Riddick's Queens residence without an arrest warrant after seeing him inside and arrested him; officers then found narcotics and related paraphernalia in a nearby chest of drawers. Both arrests were routine felony arrests, and the New York courts did not rely on exigent circumstances to justify the warrantless entries.
Procedural history
In Payton's case, New York police forcibly entered his apartment without an arrest warrant while investigating a murder and seized a shell casing in plain view. In Riddick's case, police entered his residence without an arrest warrant and arrested him, discovering narcotics during a search incident to the arrest. New York trial courts denied suppression motions, the Appellate Divisions affirmed, and the New York Court of Appeals affirmed both convictions. The Supreme Court reversed and remanded.
Remand instructions
The judgments were reversed and the cases remanded to the New York Court of Appeals for further proceedings not inconsistent with the opinion.