Mincey v. Arizona

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Following is the case brief for Mincey v. Arizona, 437 U.S. 385 (1978)

Case Summary of Mincey v. Arizona:

  • An undercover police officer and petitioner Mincey were shot during a drug bust. Mincey was tried and convicted of murder, assault, and drug offenses.
  • Mincey’s motions to suppress the fruits of a four-day search of his home, and his statements while in intensive care at the hospital were denied by the trial court and the Arizona Supreme Court.
  • The U.S. Supreme Court, however, held that the four-day search violated Mincey’s Fourth Amendment rights.  It noted that the Arizona Supreme Court’s “murder scene exception” is not a valid exception to the warrant requirement.
  • The Court also held that Mincey’s hospital statements were not voluntary.  They were obtained in violation of Miranda, and were not the result of Mincey’s rational intellect and free will.

Mincey v. Arizona Case Brief

Statement of the Facts:

  • The Undercover Drug Deal Gone Bad

Officer Headricks, operating undercover, made a narcotics deal with petitioner Mincey and indicated that he would return to Mincey’s apartment with money to complete the transaction.  Headricks later returned with nine plainclothes police officers.  Headricks knocked on Mincey’s door, and one of Mincey’s friends answered.  Although the friend tried to keep the nine officers out, Headricks was able to slip into the apartment and meet Mincey in the bedroom.

Shots were then fired and Headricks stumbled out of the bedroom, collapsing on the floor. Officers proceeded to the bedroom where they found Mincey on the floor, seriously wounded.  Mincey was later charged with murder, assault, and narcotics offenses.

  • The Four-Day Search of Mincey’s Apartment

Immediately following the shooting, the officers on the scene made sure there were no further victims in the apartment.  Beyond that, however, they left any further search to other detectives per police procedure.  The homicide detectives who took over the crime scene began a search for evidence.  The search took four days, during which detectives went extensively through the entire apartment, even cutting up parts of Mincey’s carpet.  The 200 to 300 pieces of evidence obtained were used at Mincey’s trial.

  • The Hospital Interrogation of Mincey 

At 8pm on the evening of the shooting, a detective visited Mincey’s hospital room.  Mincey was barely conscious and encumbered by various tubes and needles.  The detective read Mincey his Miranda warnings and began an interrogation.  Although Mincey requested a lawyer and that the detective stop questioning him, the detective persisted in questioning Mincey for four hours.

Procedural History:

  • Mincey moved to suppress the evidence obtained during the four-day search, and his statements during the hospital interrogation.  The trial court denied those motions. A jury then convicted Mincey on all charges.
  • On appeal, the Arizona Supreme Court reversed the murder and assault convictions, but affirmed the narcotics convictions.
  • With regard to Mincey’s motions, the court held that the search was valid under a “murder scene exception” to the Fourth Amendment.  It also held that Mincey’s statements were voluntary for impeachment purposes.
  • The U.S. Supreme Court granted certiorari.

Issue and Holding:

  1. Is a four-day warrantless search of a murder suspect’s apartment consistent with the Fourth and Fourteenth Amendments?  No.
  2. Can statements made by an intensive care patient who repeatedly asked for counsel and to cease questioning be considered voluntary?  No. 

Judgment:

The judgment of the Arizona Supreme Court is reversed and remanded.

Rule of Law or Legal Principle Applied:

  1. A “murder scene exception” to the Fourth Amendment’s warrant requirement does not exist.  Accordingly, a warrantless four-day search of a suspect’s home violates the Fourth Amendment in the absence of exigency or some other proper exception to the warrant requirement.
  2. The statements of a barely conscious intensive care patient, who repeatedly asked for counsel and to cease questioning, cannot be considered voluntary.  Accordingly, such statements cannot be used at trial for any purpose.

Reasoning:

  • The Warrantless Four-Day Search Violated the Fourth Amendment

The three arguments supporting the Arizona Supreme Court’s new “murder scene exception” to the warrant requirement are unpersuasive.  First, Mincey did not waive any right to privacy by virtue of shooting Officer Headricks.  Also, the notion that the four-day search was no more intrusive than the original entry of the nine officers into the apartment is not persuasive given how extensive the four-day search was.

Second, the fact that Mincey’s apartment was a murder scene does not mean that an emergency situation existed such that a warrant was not required.  Finally, the purported “murder scene exception” is not permissible because it is narrowly defined.  The opposite appears to be true in this case, where the searching officers had unbridled access to Mincey’s entire home.

In sum, the “murder scene exception” is inconsistent with the Fourth and Fourteenth Amendments, and therefore cannot be used to justify warrantless searches.

  • The Hospital Statements Were Not Voluntary

While statements obtained in violation of Miranda may still be admissible to impeach the person making the statements, the statements must be the result of rational intellect and free will.  In this case, the circumstances of the hospital questioning and Mincey’s condition make clear that his statements were not the product of such rational thought and free will. Accordingly, they were involuntary, and the use of those statements for any purpose at trial violates Mincey’s due process rights.

Concurring and Dissenting Opinions:

Concurring Opinion (Marshall):

Litigants do not have a federal habeas corpus remedy for Fourth Amendment violations adjudicated in state courts, pursuant to Stone v. Powell, 428 U.S. 465 (1976).  In order to clear such issues out of the Court’s docket, the Court should reconsider the Stone decision.

Concurring in part, and Dissenting in part Opinion (Rehnquist):

The Court was correct in finding a Fourth Amendment violation in the four-day search. However, the Court should not have substituted its own judgment for that of the trial court with regard to the voluntariness of Mincey’s hospital statements.  The trial court is far closer to the facts and deserves deference regarding such fact-intensive inquiries.

Significance:

Mincey v. Arizona had a significant impact on law enforcement’s ability to search a murder scene without a warrant.  Prior to Mincey, courts generally did not impose requirements on murder scene searches.  However, Justice Stewart’s careful application of the Fourth Amendment in Mincey now ensures that the parameters of a murder scene search are defined by a neutral magistrate, rather than by an interested police officer in search of incriminating evidence.

Student Resources:

https://supreme.justia.com/cases/federal/us/437/385/case.html

https://www.oyez.org/cases/1977/77-5353

http://law.jrank.org/pages/24025/Mincey-v-Arizona-Significance.html