Warden, Maryland Penitentiary v. Hayden

Warden, Maryland Penitentiary v. Hayden

United States Supreme Court
387 U.S. 294 (1967)

ISSUE: Is a comprehensive search of a residence without a warrant a violation of the 4th Amdt. if an armed robbery had just occurred and police received a tip that the alleged robber had just entered the house in question?
HOLDING: No, the exigencies of the situation made the warrantless search for the robber and weapons imperative.
FACTS:
  • An armed robber robbed Diamond Cab Company and 2 cab drivers followed him to a certain house
  • The cab dispatcher then relayed the house information to police who proceeded to the house, knocked and announced their presence, and then were allowed in
  • Police then searched the two floors and the basement and found D and his weapons and clothing throughout the house including in the washing machine
REASONING:
  • Valid warrantless search: The exigencies of the situation made the police's course imperative
    • The 4th Amdt. does not require police officers to delay in the course of an investigation if to do so would gravely endanger their lives or the lives of others
    • A thorough search of the house was necessary in order to find D and any weapons
  • Not unreasonable to search washing machine: The officer who opened the washing  machine and found D's clothes did not yet know that the weapons had been found, so the inference can be drawn that the officer was looking for weapons in the machine
OTHER CASES:
  • United States v. Santana: "Hot pursuit" justified warrantless entry into a residence
  • Welsh v. Wisconsin: It's difficult to conceive a warrantless home arrest that would not be unreasonable under the 4th Amdt. when the underlying offense is extremely minor (here, DUI)
    • Not hot pursuit because there was no immediate and continuous pursuit of the petitioner from the scene of the crime
    • Posed little remaining threat to public safety
    • Exigency based on preservation of evidence couldn't justify the warrantless entry of the home here
  • Brigham City, Utah v. Stuart: One exigency obviating the warrant requirement is the need to assist persons who are seriously injured or threatened with such injury inside a house
    • An entry is valid if the objective circumstances establish sufficient need to assist or protect an occupant

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