Officers responded to a complaint regarding a loud party at a residence. At the scene, they heard shouting from inside and observed juveniles drinking alcohol in the backyard. The officers went into the backyard and observed a physical disturbance occurring in the kitchen of the home. A juvenile suspect punched an adult victim in the face. An officer opened the screen door to the kitchen and announced his presence, though nobody noticed. The officer entered the kitchen and again stated his presence, at which time the altercation ceased. The officers arrested several adults for contributing to the delinquency of a minor, disorderly conduct, and intoxication.
Whether the officers may gain access to the premises under the emergency scene exception if their subjective intent was to enter for the purposes of effecting an arrest?
Yes. The officers’ subjective intent for entering the premises is irrelevant.
It is a “basic principle of Fourth Amendment law that searches and seizures inside a home without a warrant are presumptively unreasonable.” However, this rule is subject to a set of narrowly defined exceptions. “One exigency obviating the requirement of a warrant is the need to assist persons who are seriously injured or threatened with such injury.” The Court, therefore, held that “law enforcement officers may enter a home without a warrant to render emergency assistance to an injured occupant or to protect an occupant from imminent injury.” The officers’ intent in obtaining access to the premises is irrelevant in determining the reasonableness of the entry. “It therefore does not matter here–even if their subjective motives could be so neatly unraveled–whether the officers entered the kitchen to arrest respondents and gather evidence against them or to assist the injured and prevent further violence.” The Court stated that “[T[he role of a peace officer includes preventing violence and restoring order, not simply rendering first aid to casualties…”
547 U.S. 398, 126 S. Ct. 1943 (2006)