Facts
- During a narcotics raid at Rufus Mincey’s Tucson apartment, gunfire erupted; an undercover officer was shot and later died.
- Mincey was found in a bedroom, wounded and semiconscious.
- Officers initially conducted a brief protective sweep to locate victims and obtain medical assistance, then ceased activity.
- Homicide detectives later assumed control and conducted an extensive warrantless search of the apartment over four days, including opening drawers, tearing up carpets, and seizing 200–300 items.
- That evening, while Mincey was in intensive care, barely conscious and connected to medical equipment, a detective questioned him for hours after giving Miranda warnings.
- Mincey repeatedly asked that questioning stop and that he be allowed to consult a lawyer; questioning continued.
- At trial, Mincey was convicted of murder, assault, and narcotics offenses; key evidence for the narcotics counts came from the multi-day apartment search, and the State sought to use Mincey’s hospital statements at least for impeachment.
Issues
- Whether the Fourth and Fourteenth Amendments permit an extensive, multi-day warrantless search of a homicide scene based on a categorical “murder scene exception” to the warrant requirement.
- Whether statements obtained from a severely injured suspect in intensive care, after repeated requests to stop and to consult counsel, were voluntary and therefore admissible, including for impeachment.
Decision
- The Court rejected any general “murder scene exception” to the Fourth Amendment warrant requirement.
- The Court held the four-day warrantless search of Mincey’s apartment was unconstitutional once any emergency had ended.
- The Court held Mincey’s hospital statements were involuntary under the totality of the circumstances.
- The Court ruled involuntary statements are inadmissible for any purpose, including impeachment.
- The Court reversed the state judgment insofar as it upheld convictions dependent on the unlawful search and the involuntary statements.
Legal Principles
- A home search is presumptively unreasonable without a warrant; the seriousness of the offense, including homicide, does not itself create a categorical exception.
- Exigent-circumstances authority is limited to addressing immediate needs (e.g., locating victims, securing dangers) and does not justify prolonged, exploratory evidence gathering after the emergency is resolved.
- Voluntariness is a due process requirement assessed under the totality of circumstances, including the suspect’s physical and mental condition and police conduct.
- Statements that are involuntary are categorically inadmissible at trial, including for impeachment, even if Miranda warnings were given.
Conclusion
The Court held that police may not conduct an exhaustive warrantless home search merely because a homicide occurred and that statements extracted from a gravely injured suspect under coercive conditions are involuntary and inadmissible for any use at trial.