## Facts

- Federal deputy U.S. marshals and local sheriff’s deputies went to the Wilsons’ Maryland home early in the morning to execute an arrest warrant for their son, Dominic Wilson.
- Officers invited a newspaper reporter and photographer to accompany them during the entry as part of a media ride-along.
- The arrest warrant did not authorize or reference the presence of media or other third parties.
- Officers entered the home, awakened the Wilsons, and conducted a protective sweep; Dominic Wilson was not found.
- The reporter and photographer observed and photographed the entry but did not assist in executing the warrant; the photographs were not published.
- The Wilsons sued for damages, alleging the officers violated the Fourth Amendment by bringing third parties into the home without necessity to execute the warrant.

## Issues

1. Whether officers violate the Fourth Amendment by bringing media or other third parties into a home while executing an arrest warrant when their presence is not in aid of the warrant’s execution.
2. Whether the officers were entitled to qualified immunity because the asserted Fourth Amendment right was not clearly established at the time of the entry.

## Decision

- The Supreme Court held that bringing media members (or other third parties) into a home during execution of a warrant violates the Fourth Amendment when their presence is not in aid of the warrant’s execution.
- The Court nevertheless held the officers were entitled to qualified immunity because the unlawfulness of the conduct was not clearly established at the time.
- The Court affirmed the judgment granting qualified immunity, while resolving the underlying constitutional question on the merits.

## Legal Principles

- The Fourth Amendment’s protection of the home limits the scope of intrusion during execution of a warrant to what is related to the warrant’s objectives.
- Even when officers are lawfully inside a residence to execute an arrest warrant, they may not expand the intrusion by admitting third parties whose presence does not assist execution of the warrant.
- Qualified immunity applies unless existing law gave officers fair warning that their conduct was unconstitutional; the analysis is the same for federal officers in Bivens actions and state officers in § 1983 actions.
- A constitutional violation may be found, yet damages barred, if the right was not clearly established at the time of the events.

## Conclusion

The Court ruled that media ride-alongs inside a home during warrant execution are unconstitutional unless the third parties’ presence helps execute the warrant, but it denied damages because that rule was not clearly established when the officers entered the Wilsons’ home.


Wilson v. Layne, 526 U.S. 603 (1999)