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Keywords

defendantstatuteappealtrialfelonycommon lawseizure
appealfelonycommon law

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Payton v. New York, 445 U.S. 573, 100 S.Ct. 1371, 63 L.Ed.2d 639

Facts

In this case, two defendants, Theodore Payton and Obie Riddick, were arrested in their homes without warrants by police officers who had probable cause. In both instances, the police forcibly entered the residences without consent, leading to the seizure of evidence. The New York trial judges upheld the warrantless entries based on state statutes, which were later affirmed by the New York Court of Appeals.

On January 14, 1970, after two days of intensive investigation, New York detectives had assembled evidence sufficient to establish probable cause to believe that Theodore Payton had murdered the manager of a gas station two days earlier.

Issue

Whether the Fourth Amendment prohibits warrantless and nonconsensual entries into a suspect's home to make a routine felony arrest.

The question has been answered in different ways by other appellate courts.

Rule

The Fourth Amendment, applicable to the States via the Fourteenth Amendment, prohibits warrantless and nonconsensual entries into a suspect's home for the purpose of making an arrest, absent exigent circumstances.

The Fourth Amendment, made applicable to the States by the Fourteenth Amendment, prohibits the police from making a warrantless and nonconsensual entry into a suspect's home in order to make a routine felony arrest.

Analysis

The Court analyzed the historical context of the Fourth Amendment and the common law regarding warrantless arrests in homes. It concluded that the physical entry into a home is a significant invasion of privacy, which requires a warrant unless there are exigent circumstances. The Court emphasized that the sanctity of the home is a core principle of the Fourth Amendment.

The Court analyzed the historical context of the Fourth Amendment and the common law regarding warrantless arrests in homes.

Conclusion

The Supreme Court reversed the judgments of the New York Court of Appeals, holding that the warrantless entries were unconstitutional.

We now reverse the New York Court of Appeals and hold that the Fourth Amendment to the United States Constitution, made applicable to the States by the Fourteenth Amendment, prohibits the police from making a warrantless and nonconsensual entry into a suspect's home in order to make a routine felony arrest.

Who won?

The defendants, Payton and Riddick, prevailed because the Supreme Court found that their Fourth Amendment rights were violated by the warrantless entries into their homes.

The Supreme Court reversed the judgments of the New York Court of Appeals, holding that the warrantless entries were unconstitutional.

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