Supreme Court of the United States · 1984 · Criminal Procedure
466 U.S. 740 (1984)
Updated
Criminal ProcedureFourth AmendmentWarrantless home entryExigent circumstancesArresthomewarrantless arrestminor offense
Facts
A witness saw petitioner driving erratically, swerving off the road into a field, and then walking away from the car before police arrived. Police learned the car was registered to petitioner and, without obtaining a warrant, went to his nearby home around 9 p.m., entered the house, and found him naked in bed upstairs. They arrested him for driving or operating a motor vehicle while under the influence of an intoxicant, and he later refused a breath-analysis test. For purposes of decision, the Court assumed there was no valid consent to enter the home.
Issue
Whether the Fourth Amendment permits police to make a warrantless nighttime entry into a person's home to arrest him for a nonjailable traffic offense based on probable cause and claimed exigent circumstances. More specifically, the question was whether the circumstances here justified home entry to arrest petitioner for what the officers had to treat as a first-offense, noncriminal traffic violation.
Rule
Searches and seizures inside a home without a warrant are presumptively unreasonable. Although exigent circumstances can justify warrantless home entry, an important factor in deciding whether any exigency exists is the gravity of the underlying offense, and application of the exigent-circumstances exception in the context of home entry should rarely be sanctioned when there is probable cause to believe only a minor offense has been committed.
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One of 10 multiple-choice questions for this case. Pick an answer to see why.
In Madison, Wisconsin, a neighbor told police that Lena Ortiz had driven slowly over a curb, stopped without injuring anyone, and walked three blocks home. Officers confirmed the car was registered to Lena and, twenty minutes later, entered her apartment without a warrant to arrest her for a first-offense municipal traffic infraction punishable only by a fine, citing concern that alcohol in her body was dissipating.
Was the warrantless entry most likely constitutional?
Explanation. The majority held that searches and seizures inside the home without a warrant are presumptively unreasonable, and the government bears a heavy burden to show exigent circumstances. A key factor is the gravity of the underlying offense. When officers have probable cause to believe only a minor offense has been committed, application of the exigent-circumstances exception to enter the home should rarely be sanctioned. Dissipation of blood-alcohol evidence, standing alone, does not justify warrantless home entry where the offense is only a minor nonjailable one.