Payton v. New York
445 U.S. 573, 100 S.Ct. 1371, 63 L.Ed.2d 639 (1980)
Facts
New York detectives had assembled sufficient evidence to establish probable
cause that Defendant Payton had committed murder two days earlier. Six
officers went to Payton's apartment to arrest him. They had not obtained a
warrant. Although light and music emanated from the apartment, there was no
response to the knocks. Police summoned assistance and used crowbars to
break open the doors. No one was there, but a 30 caliber shell casing in
plain view was seized and later admitted into evidence at trial.
In another case, Defendant Riddick was arrested for two armed robberies.
He had been identified earlier by the victims. Police learned of his
address and went to his house without obtaining a warrant. Riddick's young
son opened the door, and police could see Riddick sitting in bed covered by
a sheet. Before permitting him to dress, police arrested Riddick and opened
a chest of drawers two feet from the bed in search of weapons, and found
narcotics. Riddick was subsequently indicted on narcotics charges.
The New York Court found that no exigent circumstances existed in these
cases. The New York Court also treated these cases as routine arrests where
there was ample time to gain a warrant. The High Court considered the case
in light of these facts.
The Court reversed and remanded both cases.
Question
Does the Fourth Amendment allow police to, without a warrant, enter a
private residence with force, in order to make a felony arrest.
Holding
The Court held that police could not enter a dwelling without a warrant in
order to make an arrest.
Reasoning
The Court reasoned that it is a basic principle of Fourth Amendment Law
that searches and seizures inside a home are presumptively unreasonable.
The court cited Dorman v. United States that noted that a greater burden is
placed on officials who enter a dwelling without consent. Freedom from
intrusion into the home is the foundation of Fourth Amendment rights.
The Court was unconvinced of the state's argument that a warrant based on
probable cause that the suspect is at homes provides the necessary
protection, and since this is manifestly impractical, no warrant is required.