Payton v. New York

Payton v. New York

United States Supreme Court
445 U.S. 573 (1980)

ISSUE: May a police officer enter a private residence without a warrant and with force if necessary to make a routine felony arrest, even if allowed by a state statute?
HOLDING: No.
FACTS:
  • Payton: PC to believe that Payton had murdered the manager of a gas station 2 days earlier
    • 6 officers went to Payton's apartment, knocked on the door, and then forced their way in when there was no answer
    • No one was there, but they seized a shell casing that was in plain view
  • Riddick: 4 officers knocked on Riddick's door, and his 3-year-old son opened to door and the officers entered
    • They saw Riddick in his bed and arrested him
    • Officers then searched a chest of drawers near his bed and seized weapons, narcotics, and related paraphernalia
RULES:
  • Dorman: Warrantless arrests in public places are valid
REASONING:
  • Plain language of 4th Amdt.: Plain language of the 4th Amdt. prohibits unreasonable searches and seizures conducted without a warrant, and especially ones conducted in one's own house
    • Warrantless searches and seizures inside a home are presumptively unreasonable
    • Absent exigent circumstances, a warrantless entry to search for weapons or contraband is unconstitutional even when a felony has been committed and there is PC to believe that incriminating evidence will be found within
  • Watson doesn't applyWatson only allowed warrantless arrests in public places
    • Prevailing practice at CL was not to make warrantless arrests in homes
    • Not universally accepted in the states that warrantless arrests in private homes are allowed
    • Should not disregard our nation's history

 

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