Caseflicks

Supreme Court of the United States • 1980

Payton v. New York

445 U.S. 573 | 100 S. Ct. 1371 | 63 L. Ed. 2d 639 | 1980 U.S. LEXIS 13

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Takeaway

In short, this case makes the home a constitutional threshold: absent consent or exigent circumstances, police need an arrest warrant before entering a suspect's own residence to make a routine felony arrest.

Background

After investigating the murder of a gas-station manager, New York police had probable cause to believe Theodore Payton was the killer. Without obtaining an arrest warrant, six officers went to his apartment, knocked, received no response, and forcibly entered about 30 minutes later. Payton was not there, but officers saw and seized a shell casing in plain view. That casing was admitted at his murder trial.

In a companion case, police had probable cause to believe Obie Riddick had committed two armed robberies. Without an arrest warrant, officers went to the house where he lived, saw him in bed after his young son opened the door, entered, and arrested him. While Riddick was dressing, officers searched a nearby drawer and found narcotics.

New York statutes authorized warrantless entry, including forcible entry after appropriate notice or under specified circumstances, to make felony arrests. The trial courts denied suppression in both cases, and the Appellate Divisions affirmed. The New York Court of Appeals consolidated the cases and upheld the convictions, reasoning that entry to arrest was less intrusive than entry to search for evidence and that the public interest in apprehending felony suspects justified the practice. The Supreme Court reversed.

Issues

Issue #1

Whether the Fourth Amendment permits police, absent consent or exigent circumstances, to enter a suspect's own home without a warrant to make a routine felony arrest.

Holding

No. The Fourth Amendment prohibits a warrantless and nonconsensual entry into a suspect's home to make a routine felony arrest, absent exigent circumstances.

Reasoning

The Court began with the Fourth Amendment's protection against unreasonable searches and seizures. An arrest is plainly a seizure of a person, and the Amendment applies to seizures of persons just as it applies to seizures of property. The established rule is that searches and seizures inside a home without a warrant are presumptively unreasonable unless a recognized exception, such as exigent circumstances, applies.

The home receives the Amendment's most forceful protection. A public arrest on probable cause may be reasonable without a warrant, as United States v. Watson held, but crossing a home's threshold creates an additional and distinct invasion: intrusion into the resident's private dwelling. The Court described that threshold as a firm constitutional line that police ordinarily may not cross without a warrant.

New York argued that arrest entries are less intrusive than searches for evidence because an arrest does not necessarily entail rummaging through possessions. The Court rejected that distinction as insufficient. An officer entering to arrest may have to search the residence for the suspect, and, in any event, both an arrest entry and a search entry share the central intrusion—the breach of the home's entrance. Any difference between the two is one of degree, not constitutional kind.

History did not establish a settled common-law rule authorizing the warrantless home arrests at issue. The common-law sources were divided, and influential authorities, including Coke, treated a warrantless forced entry with substantial skepticism. The historical materials instead reflected a deep and repeated commitment to the principle that a person's home is his or her castle.

The state-law practice and federal legislation cited by New York did not supply the strong historical and legislative consensus that had supported warrantless public felony arrests in Watson. States were divided, with a recent trend toward requiring warrants for home arrests, and no federal statute clearly expressed a congressional judgment that warrantless entries into homes to make routine arrests were reasonable.

The Court did not decide whether exigent circumstances could have justified the officers' entries, because the New York courts treated both cases as routine arrests in which there was time to obtain warrants. It also did not address entry into a third party's home, the quantum of proof needed to believe a suspect is present, or entries made with an occupant's consent.

Issue #2

What warrant authority is sufficient for police to enter a suspect's own dwelling to execute an arrest?

Holding

An arrest warrant, supported by probable cause, implicitly authorizes limited entry into the dwelling where the suspect lives when officers have reason to believe the suspect is within; a separate search warrant is not required for that limited purpose.

Reasoning

The Court rejected New York's argument that, because a search warrant based on probable cause to believe the suspect is presently at home would be impractical, no warrant should be required. The constitutional function of a warrant is to interpose a neutral magistrate between the officer and the home, and an arrest warrant supplies that protection by requiring a judicial finding of probable cause that the person committed the offense.

An arrest warrant does not authorize a general evidentiary search. Rather, it carries limited authority to enter the suspect's own residence when there is reason to believe the suspect is inside, for the purpose of arresting that person. Because police obtained no arrest warrants for either Payton or Riddick, the judgments had to be reversed and remanded.

Concurrences

Justice Blackmun

Reasoning

Justice Blackmun emphasized that Payton complements rather than undermines United States v. Watson. He continued to believe that a warrantless public arrest based on probable cause is constitutional, but concluded that the balance changes when officers seek to arrest a person inside the person's home. There, absent exigent circumstances, the suspect's interest in the sanctity of the home outweighs the government's interest in dispensing with a warrant.

Dissents

Justice White

Reasoning

Justice White, joined by Chief Justice Burger and Justice Rehnquist, argued that the majority adopted an inflexible warrant rule with little support in the common law, the Fourth Amendment's text, or its history. In his view, common-law authorities generally recognized a constable's authority to enter a dwelling to arrest a suspected felon, even though commentators differed about the precise limits of that authority.

He maintained that the Fourth Amendment was principally a reaction against abusive general warrants, not an effort to restrict traditional warrantless felony-arrest authority. On this account, the Amendment preserved the common-law rule against unreasonable intrusions while imposing particularity and probable-cause limits on warrants that expanded official power.

Justice White also stressed that warrantless home arrests were long accepted in many states and were authorized by numerous state statutes. He regarded that widespread practice, along with federal statutes authorizing warrantless felony arrests, as substantial evidence that such arrests were constitutionally reasonable.

In his view, the majority overstated the additional intrusion caused by a home arrest. A rule limiting warrantless entries to daytime felony arrests, requiring officers to knock and announce, and requiring probable cause both of the suspect's guilt and presence in the dwelling would protect privacy adequately. Those limits would often allow the suspect to surrender at the door, avoiding any meaningful search of the home.

Finally, Justice White warned that the warrant requirement would burden police and courts by forcing officers to make difficult, time-sensitive judgments about whether exigent circumstances existed. He would have held that, after knocking and announcing, police may make a daytime warrantless home arrest when they have probable cause to believe the suspect committed a felony and is present in the home.

Justice Rehnquist

Reasoning

Justice Rehnquist separately joined Justice White's dissent and expressed particular concern about the practical consequences of excluding evidence in cases involving serious violent crimes. He noted that Payton's case involved murder and Riddick's involved armed robberies, and questioned a criminal-justice system in which convictions for such offenses were set aside through the Fourth Amendment exclusionary rule.

He also endorsed Justice White's historical objection. Even accepting prior warrant-rule doctrine as precedent, he believed the Court improperly extended that doctrine to arrests of suspected felons in their homes when police had probable cause to believe they committed the offenses.