Payton v. New York
Following is the case brief for Payton v. New York, United States Supreme Court, (1980)
Case summary for Payton v. New York:
- Theodore Payton and Obie Reddick each had evidence seized from their home absent a warrant.
- The state trial court introduced the seized evidence and the state supreme court upheld their convictions.
- Both defendants appealed their convictions to the United States Supreme Court.
- The Court held that without a warrant, officers cannot enter a person’s home to place them under arrest when no exigent circumstances exist. As a result, the subsequent seizure of items found in the home of the accused was also wrongful, absent exigent circumstances.
Payton v. New York Case Brief
Statement of the facts:
Absent a warrant, police officers showed up at Payton’s home after believing they had established probable cause that he had committed a murder. When Payton failed to immediately answer the door, the officers broke into the home and seized gun shell casing under the plain view doctrine. The gun shells were introduced into evidence despite defendant’s objections, as the trial court held that under New York law, the police were permitted to break into the defendant’s home.
In a similar case, Riddick was arrested for an alleged armed robbery when the police arrived at his home without a warrant. After his son answered the door, the police entered Riddick’s home and arrested him. The police also seized drugs they found in Riddick’s dresser and the New York trial judge held up both the search and entry of Riddick’s home as lawful under state law.
The New York court of appeals upheld both Payton’s and Riddick’s convictions. Both appealed to the Supreme Court of the United States.
Rule of Law or Legal Principle Applied:
Police officers may not enter a person’s home to place them under arrest without a warrant, in the absence of exigent circumstances.
Issue and Holding:
Whether the police may enter a suspect’s home, absent a warrant, to make an arrest? No.
The United States Supreme Court reversed and remanded the state courts judgments.
The Fourth Amendment prohibits unreasonable searches and seizures of property and people. This protection applies to the states through the 14th Amendment. The Court held that the intent behind creating the Fourth Amendment was to protect against indiscriminant abuse of police officer authority.
The Court also held there is no uniform agreement among the states regarding the legality of warrantless arrests in a suspect’s own home. In addition, congress has not claimed that entering a private home, absent a warrant, to arrest the owner is reasonable. It follows that doing such absent a warrant is presumptively unreasonable when officers are entering the home to seize items or property. The Court also held it is unreasonable for officers to enter the home of the accused, absent a warrant, to place the accused under arrest.
Here, each warrantless entry into the homes or Payton and Riddick are unreasonable as it the arrest of Riddick. Each equates to a blatant Fourth Amendment right to privacy violation.
Concurring or Dissenting opinion:
There exists little historical support for today’s decision. At common law, an arrest absent a warrant had to be for a felony, during the day and after the police knocked and announced their presence. Additionally, the police had to have established probable cause. These requirements already warrant sufficient protections and a new constitutional standard is not required.
This case established that absent exigent circumstances, the threshold of a suspect’s home may not be reasonably crossed absent a search warrant. Doing so violates the Fourth Amendment, as it applies to the states through the 14th Amendment.