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appealtrial

appealrespondent

Related Cases

Maryland v. Buie, 494 U.S. 325, 110 S.Ct. 1093, 108 L.Ed.2d 276, 58 USLW 4281

Facts

On February 3, 1986, two men committed an armed robbery at a Godfather's Pizza restaurant in Prince George's County, Maryland, one of whom was wearing a red running suit. Police obtained arrest warrants for Jerome Edward Buie and his suspected accomplice, Lloyd Allen. On February 5, police executed the warrant at Buie's home, where Buie was arrested after emerging from the basement. An officer then entered the basement to check for any additional individuals and seized the red running suit, which was later introduced as evidence in Buie's trial for armed robbery and weapons offenses.

Following a Maryland armed robbery by two men, one of whom was wearing a red running suit, police obtained arrest warrants for respondent Buie and his suspected accomplice and executed the warrant for Buie at his house.

Issue

What level of justification is required under the Fourth Amendment for police officers to conduct a protective sweep of a home during an in-home arrest?

Rule

The Fourth Amendment permits a properly limited protective sweep in conjunction with an in-home arrest when the searching officer possesses a reasonable belief based on specific and articulable facts that the area to be swept harbors an individual posing a danger to those on the arrest scene.

Analysis

The Court determined that the police had a legitimate interest in ensuring their safety during the arrest of Buie, especially given the potential for hidden accomplices in the home. The Court distinguished this case from previous rulings that required probable cause for searches, stating that a protective sweep is justified by reasonable suspicion rather than probable cause. The Court emphasized that the protective sweep should be limited to a cursory inspection of areas where a person might be hiding and should not extend beyond what is necessary to dispel the suspicion of danger.

The police had an analogous interest in taking steps to assure themselves that Buie's house was not harboring other persons who were dangerous and who could unexpectedly launch an attack, and the fact that Buie had an expectation of privacy in rooms that were not examined by the police prior to the arrest does not mean that such rooms were immune from entry.

Conclusion

The Supreme Court vacated the judgment of the Maryland Court of Appeals and remanded the case for further proceedings consistent with its opinion, establishing that reasonable suspicion is sufficient for a protective sweep during an in-home arrest.

We therefore vacate the judgment below and remand this case to the Court of Appeals of Maryland for further proceedings not inconsistent with this opinion.

Who won?

The State of Maryland prevailed in the Supreme Court, as the Court ruled in favor of allowing protective sweeps based on reasonable suspicion rather than the stricter probable cause standard previously applied by the Maryland Court of Appeals.

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