Officers received a report there was a rumor circulating that a particular student had threatened to “shoot up” his school. The officers went to the school and discovered the student had been absent the last two days and had been a bullying victim. The officers went to the student’s home, knocked on the door several times, but received no response. The officers then made phone calls to the home, but no one answered. Eventually, the student’s mother answered her cell phone and told the officers that she was inside the home with her child. When the officer asked to speak to her and the child, the mother hung up. Moments later, she and her child came out of the house and stood on the front steps. The officers told the mother why they were there and requested to go inside the house to discuss the matter. When the mother refused, one of the officers asked if there were any guns in the house. Instead of answering the question, the mother turned around and ran into the house. The officers followed the mother inside the house. After discussing the matter with her, the officers discounted the rumor concerning her child “shooting up” the school and left the house. The mother sued the officers, claiming they violated the Fourth Amendment by entering her house without consent, a warrant or an exigency.
Whether the officers were reasonable in making an entry into the home?
Yes. Several articulable factors indicated that the officers should have been concerned for their safety as well as other persons
Courts take special caution when officer safety requires prompt entry into a home; however, the court added, “No decision of this Court has found a Fourth Amendment violation on facts even roughly comparable to those present in this case.” Here, the officers could articulate several factors that could reasonably lead them to believe there was an imminent threat of violence: the unusual behavior of the mother in not answering the door or the telephone; the mother did not inquire about the reason for the officers’ visit; she hung up the telephone on the officer; she refused to tell the officers whether there were guns in the house; she ran back into the house while being questioned; her son was the victim of bullying; he had been absent from school for two days; and he supposedly threatened to “shoot up” the school. Based on these facts, the Court found the officers’ warrantless entry into the home was reasonable.
565 U.S. 469, 132 S. Ct. 987 (2012)