Flippo v. West Virginia

The Court held that after a homicide crime scene is secured for investigation, the officers may not make a warrantless search of the crime scene area. The Court reaffirmed its long held position that there is no such “homicide crime scene” exception. In Mincey v. Arizona, the Court noted that officers may make warrantless entries into premises if they reasonably believe a person is in need of immediate aid and may make prompt warrantless searches of a homicide scene for possible other victims or a killer on the premises. However, the Court explicitly rejected any general “murder scene,” “homicide scene,” or “crime scene” exception to the Fourth Amendment’s warrant requirement. The officers would have been entitled to remove the victims for medical attention, secure the premises, and then obtain a warrant to conduct a search.