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
- 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.
- Whether evidence obtained following such entries must be suppressed as the product of an unconstitutional search and seizure.
- 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.