Warden v. Hayden
Facts
An armed robber fled from the Diamond Cab Company, and cab drivers followed him to 2111 Cocoa Lane while reporting that he was a Negro about 5'8" tall, wearing a light cap and dark jacket. Police arrived within minutes, entered the house, and searched for the armed suspect and weapons. They found Hayden upstairs, and during the search officers also found a shotgun and pistol in a bathroom flush tank, a cap and pistol ammunition under Hayden's mattress, shotgun ammunition in a bureau drawer, and a jacket and trousers matching the robber's clothing in a washing machine. Those items were introduced against Hayden at trial.
Issue
Whether officers who lawfully entered and searched a house under exigent circumstances for a fleeing armed robber could seize clothing found there and use it at trial when the clothing was allegedly only 'mere evidence.' Also, whether the search that produced the clothing was within the permissible scope of the exigent search.
Rule
The Fourth Amendment does not recognize a distinction between 'mere evidence' and instrumentalities, fruits of crime, or contraband for purposes of seizure. If a search is otherwise lawful, items of evidential value may be seized so long as the Fourth Amendment's protections are satisfied, including a nexus between the item seized and criminal behavior; in the case of mere evidence, there must be probable cause to believe the evidence sought will aid in a particular apprehension or conviction.
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Was the warrantless entry and search of the duplex most likely constitutional?