## Facts

- A California Highway Patrol officer saw Arthur Gregory Lange drive by while playing loud music and repeatedly honking his horn.
- The officer followed Lange and turned on overhead lights to signal him to pull over.
- Rather than stopping immediately, Lange drove about 100 feet to his driveway and entered his attached garage, which was part of his home.
- Without a warrant, the officer followed Lange into the garage and questioned him.
- The officer observed signs of intoxication and conducted field sobriety testing, which Lange failed.
- A later blood test showed Lange’s blood alcohol content was more than three times the legal limit.
- California charged Lange with misdemeanor driving under the influence of alcohol.
- Lange moved to suppress evidence obtained after the officer entered the garage, arguing the warrantless entry violated the Fourth Amendment.
- The California Court of Appeal affirmed denial of suppression, reasoning that Lange’s failure to promptly pull over gave probable cause to arrest him for the misdemeanor of failing to comply with a police signal and that pursuit of a fleeing misdemeanant justified the officer’s warrantless entry.
- The California Supreme Court denied review, and the U.S. Supreme Court granted certiorari to resolve a split over whether pursuit of a suspected misdemeanant categorically permits warrantless home entry.

## Issues

1. Whether, under the Fourth Amendment, pursuit of a person whom an officer has probable cause to believe committed a misdemeanor categorically qualifies as an exigent circumstance allowing warrantless entry into a home.

## Decision

- The Supreme Court held unanimously that pursuit of a fleeing misdemeanor suspect does not categorically justify warrantless entry into a home.
- The Court vacated the California Court of Appeal’s judgment and remanded for application of a case-by-case exigent-circumstances analysis.
- The Court did not decide whether exigent circumstances existed on these facts because the lower court relied on an across-the-board rule rather than a fact-specific inquiry.

## Legal Principles

- A warrant is ordinarily required to enter a home (including areas treated as part of the home, such as an attached garage) without consent.
- The exigent-circumstances exception allows warrantless entry only when an urgent law-enforcement need makes it impracticable to obtain a warrant.
- Exigency is evaluated under the totality of the circumstances; it is generally not governed by rigid offense-based rules.
- “Hot pursuit” can be relevant to exigency, but pursuit of a misdemeanant is not automatically an exigency in every case.
- Misdemeanors range widely in conduct and seriousness, so flight from a misdemeanor stop does not always create an emergency justifying home entry.
- Examples of circumstances that may support exigency include imminent threats to safety, imminent destruction of evidence, or a meaningful risk the suspect will escape.
- When those conditions are absent and officers have time to obtain a warrant, the Fourth Amendment requires them to do so before entering the home.

## Conclusion

Lange v. California rejects a categorical rule that hot pursuit of a suspected misdemeanant always permits warrantless entry into a home, requiring courts instead to assess whether the specific situation presented an actual emergency that made getting a warrant impracticable.


Lange v. California, 594 U.S. 295, 141 S. Ct. 2011, 210 L. Ed. 2d 486 (2021)