Facts
- Police obtained warrants for Donald Vale’s arrest and surveilled the residence where he lived.
- Officers observed what they believed to be a narcotics transaction between Vale and a known addict.
- Vale was arrested on the front steps/outside the house.
- After the arrest, officers announced they would search the house and conducted a warrantless search of the unoccupied dwelling.
- Police found narcotics in a bedroom; the drugs were introduced at trial.
Issues
- Whether a warrantless search of a home is valid as a search incident to arrest when the arrest occurs outside the home.
- Whether the warrantless home search was justified by exigent circumstances based on a general risk that narcotics could be destroyed.
Decision
- The Supreme Court reversed and remanded.
- The Court held the warrantless search of the house violated the Fourth Amendment as applied to the states through the Fourteenth Amendment.
- The search was not a valid search incident to arrest because the arrest occurred outside the house.
- The State failed to show facts supporting a recognized exception to the warrant requirement, including exigent circumstances.
Legal Principles
- Warrantless searches of a home are presumptively unreasonable and permissible only under a few specifically established, well-delineated exceptions.
- A search of a house cannot be upheld as incident to arrest when the arrest takes place outside the house; to qualify on that theory, the arrest must occur inside the dwelling.
- The mere presence of narcotics and the general possibility of destruction of evidence do not, without concrete supporting facts, create exigent circumstances sufficient to justify a warrantless home search.
Conclusion
Because Vale was arrested outside the residence and the State did not prove a fact-specific exigency, the warrantless search of the home was unconstitutional, requiring reversal of the conviction based on the admitted narcotics evidence.