Vale v. Louisiana

Vale v. Louisiana

United States Supreme Court
399 U.S. 30 (1970)

ISSUE: May police officers search a house as incident to arrest if D was arrested outside the house on the front steps for allegedly selling narcotics?
HOLDING: No.
FACTS:
  • Police had 2 arrest warrants for D and went to his house
  • They observed a car pull up to the house, honk the horn, D come out to the car, go back into the house, and then return to the car again
  • Officers suspected a narcotics sale was in progress so they moved in to arrest D
  • D ran towards the house, and the officers shouted that he was under arrest
  • Officers then proceeded to enter the house, search, and find narcotics in a back room
PROCEDURAL HISTORY:
  • Louisiana Supreme Court upheld the search as incident to arrest
RULES:
  • Chimel: A search of a dwelling incident to arrest must be confined to the area within the arrestee's reach at the time of the arrest
  • Shipley: A search may be incident to an arrest only if it is substantially contemporaneous with the arrest and is confined to the immediate vicinity of the arrest
REASONING:
  • Not search incident to arrest: For a search of a house to be incident to arrest, the arrest must occur inside the house, not outside
  • Should have got a warrant: The officers had sufficient PC to secure a search warrant, so they should have done that
    • An arrest on the street cannot provide its own "exigent circumstance" so as to justify a warrantless search of the arrestee's house
DISSENT:
  • The delay in seeking a search warrant would have provided anyone in the house with ample time to destroy the narcotics located there
  • The arrest warrants were only for increased bond, so the officers had no PC to secure a search warrant beforehand
OTHER CASES:
  • Illinois v. McArthur: Two officers accompanied a woman to her trailer to keep the peace while she removed her belongings, and upon leaving, she told the officers that her husband had dope in the trailer.  When one officer left to get a search warrant, the husband exited, and the other officer prevented him from re-entering until the officer returned with the warrant.
    • Warrantless seizure of the premises was not per se unreasonable because it involved a plausible claim of exigent circumstances, and the restraint at issue was tailored to that need, being limited in time and scope
    • Since the officers didn't enter the trailer without a warrant, the intrusion upon the privacy interest was relatively minor and outweighed by the law enforcement interest at stake
    • A person standing in the doorway is in a public place

 

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