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LEGAL

RESEARCH

Payton v. New York

Facts

Officers developed probable cause the defendant murdered the manager of a gas station two days earlier. Six officers went to his apartment intending to arrest him. The officers did not have a warrant. Although light and music emanated from the apartment, there was no response to the officers’ knock on the metal door. The officers summoned additional assistance and, about thirty minutes later, used crowbars to break open the door and enter the apartment. No one was there. However, the officers found a .30 caliber shell casing that was later admitted into evidence at the defendant’s murder trial.

Issue

Whether the warrantless entry into the apartment was reasonable?

Held

No. The physical entry into the home is the chief evil against which the wording of the Fourth Amendment is directed.

Discussion

Arrest in the home involves not only the invasion associated to all arrests, but also an invasion of the sanctity of the home. The law has long held that this is too substantial an invasion to allow without a warrant or exigent circumstances.

This applies equally to seizures of property. Absent exigent circumstances, that threshold may not reasonably be crossed without a warrant. It is a basic principle of Fourth Amendment law that searches and seizures inside a home without a warrant are presumptively unreasonable.

Citation

445 U.S. 573, 100 S. Ct. 1371 (1980)

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