## Facts

- New York statutes authorized police to enter a private residence, using force if necessary, to make a felony arrest without a warrant.
- Police had probable cause to arrest Theodore Payton for murder but obtained no arrest warrant and no search warrant.
- Officers went to Payton’s apartment, forcibly entered after no answer, and seized a shell casing in plain view; Payton was not present.
- Payton sought suppression; the trial court denied suppression based on the statutes and plain-view doctrine.
- Police had probable cause to arrest Obie Riddick for robbery, went to his apartment without a warrant, entered when the door was opened, and arrested him.
- During a search of the immediate area, officers opened a nearby drawer and found narcotics, leading to drug charges.
- Riddick sought suppression; the trial court denied suppression based on the statutes and upheld the search incident to arrest.
- The New York Court of Appeals treated both as routine arrests with time to obtain warrants and affirmed the convictions.

## Issues

1. Whether the Fourth Amendment permits warrantless and nonconsensual entry into a suspect’s home to make a routine felony arrest based solely on probable cause, absent exigent circumstances.
2. Whether evidence obtained following such entries must be suppressed as the product of an unconstitutional search and seizure.
3. Whether, and to what extent, an arrest warrant (as opposed to a search warrant) authorizes entry into a suspect’s own dwelling to effectuate an arrest.

## Decision

- The Supreme Court reversed (6–3) and held the Fourth Amendment prohibits warrantless, nonconsensual home entry to make a routine felony arrest absent exigent circumstances.
- The Court invalidated the New York statutes to the extent they authorized such entries without a warrant and without exigency.
- The Court emphasized a “firm line” at the home’s threshold: entry generally requires a warrant unless exigent circumstances exist.
- The Court distinguished warrantless public arrests supported by probable cause from warrantless home entries.
- The Court stated that an arrest warrant supported by probable cause provides limited authority to enter a suspect’s residence when there is reason to believe the suspect is inside.

## Legal Principles

- The home receives the highest Fourth Amendment protection; physical entry is the primary intrusion the Amendment targets.
- Probable cause alone does not justify nonconsensual entry into a home to arrest; a warrant is required absent exigent circumstances.
- Exigent circumstances may permit warrantless home entry (e.g., imminent flight or danger to life), but routine arrests with time to obtain a warrant do not qualify.
- An arrest warrant authorizes limited entry into a 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.

## Conclusion

Payton held that the Fourth Amendment generally bars warrantless, nonconsensual entry into a suspect’s home to make a routine felony arrest, and that such entries require a warrant unless exigent circumstances are present; an arrest warrant, with reason to believe the suspect is inside, suffices for limited entry into the suspect’s residence.


Payton v. New York, 445 U.S. 573 (1980)