Facts
- On March 17, 1962, an armed robber took about $363 from a Baltimore cab company.
- Cab drivers pursued the suspect to 2111 Cocoa Lane and reported he had just entered the house; police were told the suspect was a Black man wearing a light cap and dark jacket.
- Police arrived within minutes, knocked, identified themselves, and told Mrs. Hayden they believed a robber had entered; she indicated she did not object to a search.
- Officers entered without a warrant and searched the house while looking for the suspect, weapons, and the stolen money.
- Police arrested Hayden in an upstairs bedroom and continued searching to ensure no other persons or weapons posed an immediate threat.
- Officers found clothing in a washing machine matching the robber’s reported outfit, and found a shotgun, a pistol, and ammunition hidden in the house.
- At Hayden’s bench trial for armed robbery, the clothing and other items were admitted; on appeal, the clothing was challenged as inadmissible “mere evidence.”
Issues
- Whether the Fourth Amendment permits warrantless entry and search of a home when police are in immediate pursuit of a suspected armed felon believed to have just entered.
- Whether the Fourth Amendment prohibits seizure of items that have only evidentiary value, as distinct from fruits, instrumentalities, contraband, or weapons.
- Whether admitting seized clothing as evidence violates the Fifth Amendment privilege against self-incrimination.
Decision
- The Supreme Court reversed the court of appeals and upheld the search and seizure.
- The Court held that exigent circumstances in hot pursuit justified the warrantless entry and search of the house.
- The Court rejected the “mere evidence” rule and held the Fourth Amendment does not require a categorical bar on seizing items solely because they are evidence.
- The Court held seizure and use of the clothing did not violate the Fifth Amendment because the clothing was not testimonial or communicative.
Legal Principles
- Police may enter and search a home without a warrant when exigent circumstances exist, including hot pursuit of a suspected armed felon who entered moments earlier, and a reasonable need to secure persons and weapons.
- The Fourth Amendment’s limits turn on the reasonableness and lawful scope of the search, not on whether the item seized is “mere evidence” versus an instrumentality, fruit, or contraband.
- The Fourth Amendment permits seizure of evidentiary items when officers are lawfully searching and have probable cause to believe the items will aid a particular apprehension or conviction.
- Seizure and admission of physical evidence that is not testimonial does not compel self-incrimination under the Fifth Amendment.
Conclusion
The Court upheld a warrantless home entry and search based on hot pursuit and immediate safety concerns, and it eliminated the Fourth Amendment distinction that barred seizure of items with only evidentiary value, allowing such evidence to be seized and used when the search is otherwise lawful and properly limited.