Officers developed probable cause the defendant had marijuana in his home. While some of the officers sought a search warrant with this information, others prevented the defendant from entering his home unless accompanied by a law enforcement officer. This prohibition lasted for approximately two hours. Once a warrant was secured, the officers entered the home and found drug paraphernalia and marijuana
Whether the officers’ denial of the defendant access to his home without the accompaniment of an officer was an unreasonable seizure of the dwelling?
No. The brief seizure, given the circumstances, was reasonable under the Fourth Amendment.
The Court found that the warrantless seizure was reasonable since it involved exigent circumstances. The restraint employed by the officers was adapted to the circumstances, avoiding significant intrusion into the home itself. The Court balanced the privacy-related and law enforcement-related concerns. The officers had probable cause to believe the defendant’s home contained evidence, and had valid reason to fear that, unless restrained, the defendant would destroy it before other officers could return with a warrant. The officers made reasonable efforts to reconcile their needs with the demands of personal privacy, and imposed the restraint for a limited period, two hours. Given the nature of the intrusion and the law enforcement interest at stake, the brief seizure of the premises was permissible.
531 U.S. 326, 121 S. Ct. 946 (2001)