Brigham City v. Stuart

Supreme Court of the United States · 2006 · Criminal Procedure

547 U.S. 398 (2006)

Updated July 27, 2026

Criminal ProcedureFourth AmendmentWarrantless Home EntryExigent CircumstancesEmergency Aidhome entrywarrantless entryreasonableness

Facts

At about 3 a.m., four police officers responded to a complaint about a loud party at a house. After hearing shouting and entering the backyard, they looked through a screen door and windows and saw a fight in the kitchen in which several adults were trying to restrain a juvenile. The juvenile broke free, punched an adult in the face, and the officers saw the adult spit blood into a sink while the struggle continued and the juvenile was pressed against a moving refrigerator. One officer opened the screen door, announced the police presence, and then entered the kitchen when no one responded amid the continuing tumult.

Issue

Whether the Fourth Amendment permits police officers to enter a home without a warrant when they have an objectively reasonable basis for believing that an occupant is seriously injured or imminently threatened with such injury. Also, whether the officers' subjective motives or the relative seriousness of possible offenses made the entry unreasonable.

Rule

A warrantless entry into a home is objectively reasonable under the Fourth Amendment when officers have an objectively reasonable basis for believing that an occupant is seriously injured or is imminently threatened with such injury. The officer's subjective motivation is irrelevant to that inquiry, and officers need not wait until someone is unconscious or more gravely injured before acting to prevent further violence.

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One of 10 multiple-choice questions for this case. Pick an answer to see why.

At 1:30 a.m. in Columbus, officers responded to repeated 911 hang-up calls from a duplex. Standing on the public walkway, they heard screaming, glass breaking, and a man yelling, "let go of me," and through a side window saw Nina Flores shove Omar Tate into a cabinet while he held his bleeding forehead. The officers shouted from the open back porch, but the struggle continued without any acknowledgment.

Were the officers' warrantless entry into the duplex most likely constitutional under the Fourth Amendment?

Explanation. A warrantless home entry is reasonable when officers have an objectively reasonable basis for believing an occupant is seriously injured or imminently threatened with such injury. Here, the officers heard a violent disturbance and saw an active physical assault with visible bleeding. Under the majority's reasoning, officers need not wait until the harm becomes more severe, and they need not stand by after announcing themselves while the violence continues.