Payton v. New York

Jump to content

From Wikipedia, the free encyclopedia

1980 United States Supreme Court case

Payton v. New York, 445 U.S. 573 (1980), was a United States Supreme Court case concerning warrantless entry into a private home in order to make a felony arrest . The Court struck down a New York statute providing for such warrantless entries because the Fourth Amendment draws a firm line at the entrance to the house. Absent exigent circumstances , that threshold may not be reasonably crossed without a warrant. The court, however, did specify that an arrest warrant (as opposed to a search warrant ) would have sufficed for entry into the suspect's residence if there had been reason to believe that the suspect was within the home.

Payton and related case law establish that the principle that a person in a home, particularly his or her own, is entitled to Fourth Amendment protections not afforded to persons in automobiles, as per _Whren v. United States _, or to persons in public, as per _United States v. Watson _.

Background

[(https://en.wikipedia.org/w/index.php?title=Payton_v._New_York&action=edit&section=1 "Edit section: Background")
]

Theodore Payton

[(https://en.wikipedia.org/w/index.php?title=Payton_v._New_York&action=edit&section=2 "Edit section: Theodore Payton")
]

On January 14, 1970, police in New York had gathered enough evidence to establish probable cause that Theodore Payton murdered a gas station manager. Before acquiring an arrest warrant, officers arrived at Payton's apartment the next morning with the intention of arresting him. The police believed someone was inside, but there was no answer when the officers knocked on the door. The officers gained access to Payton's apartment using a crowbar. Although Payton was not home, police still seized a .30-caliber shell casing that was in plain view. Eventually, Payton later surrendered to police custody and was indicted for murder, with the .30-caliber shell casing having been admitted as evidence against him. Payton moved to have the shell casing suppressed, but the trial judge deemed it admissible. Supporting this determination, the judge cited the New York Code of Criminal Procedure as authorizing the warrantless entry into Payton's residence and the plain view doctrine as authorizing the seizure of the shell casing.

Obie Riddick

[(https://en.wikipedia.org/w/index.php?title=Payton_v._New_York&action=edit&section=3 "Edit section: Obie Riddick")
]

In June 1973, Obie Riddick was identified by victims of an armed robbery that occurred two years prior. About a year later, police learned of Riddick's address in Queens.

On March 14, 1974, law enforcement officers, without acquiring an arrest warrant, knocked on the door of Riddick's home.

Riddick's three-year-old son answered the door and police saw Riddick sitting inside the home, at which point they entered and arrested him.

In the course of his arrest, police searched the area surrounding Riddick and discovered narcotics.

Riddick was later indicted on the narcotics charge and moved to suppress the evidence against him, but the trial judge deemed the evidence admissible. Supporting this determination, the judge cited the revised New York statute as authorizing the warrantless entry into Riddick's residence and _Chimel v. California _, 395 U.S. 752 (1969), as authorizing the warrantless search of Riddick's immediate area incident to arrest.

Consolidation of Cases

[(https://en.wikipedia.org/w/index.php?title=Payton_v._New_York&action=edit&section=4 "Edit section: Consolidation of Cases")
]

On appeal to the New York Court of Appeals, the two cases were consolidated, and the convictions of both defendants were affirmed.

The New York Court of Appeals reasoned that not only were the actions of law enforcement authorized by the statutes, but also that the privacy interests involved in a warrantless entry into the home for the purpose of arrest are significantly less than if the purpose were to conduct a warrantless search.

Decision

[(https://en.wikipedia.org/w/index.php?title=Payton_v._New_York&action=edit&section=5 "Edit section: Decision")
]

On April 15, 1980, the Supreme Court of the United States issued a 6-3 decision in favor of defendants Payton and Riddick and finally answered the constitutional question that had yet to be settled: "whether and under what circumstances may an officer enter a suspect's home to make a warrantless arrest." This issue was expressly left open by prior Supreme Court cases such as _United States v. Watson _, 423 U.S. 411 (1976), which addressed warrantless arrests made in public, and United States v. Santana, 427 U.S. 38 (1976), which addressed warrantless arrests made in private homes when exigent circumstances exist.

Justice John Paul Stevens , the author of the Supreme Court's majority opinion

Opinion of the Court

[(https://en.wikipedia.org/w/index.php?title=Payton_v._New_York&action=edit&section=6 "Edit section: Opinion of the Court")
]

Justice John Paul Stevens authored the Court's majority opinion and was joined by five other justices. The Court began by emphasizing the issues that were not present in this case. The court stated that exigent circumstances were not implicated because the New York courts treated the case as "involving routine arrests in which there was ample time to obtain a warrant."

Additionally, the court clarified that the holding of this case was limited to warrantless entry's into the suspect's home, not a third party's.

After first establishing that the Fourth Amendment protects against unreasonable searches and seizures, the Court explained the importance of warrants in minimizing the risk of such a search or seizure being found unreasonable. The Court explained that, since the arrest of a person constitutes a seizure, and the Fourth Amendment applies equally to the seizure of people and property, their decision would be guided by established rules from Fourth Amendment case law involving property.

Next, the Court recognized the well-established principle of the Fourth Amendment that warrantless searches and seizures inside the home are presumptively unreasonable. However, the Court noted that this same principle does not apply to warrantless searches and seizures in public or when the property is in plain view, since no invasion of the owner's privacy is required to see it. The Court argued that these rules guiding searches and seizures of property inside the home must be extended to protect against warrantless seizure of persons inside the home as well, if the privacy interests of the home are to be preserved. The Court disagreed with the New York Court of Appeals' position that the intrusiveness of entering a suspect's home to search for property is significantly higher than searching for a person because both "share this fundamental characteristic: the breach of the entrance to an individual's home."

…