Payton v. New York case brief summary
445 U.S. 573
SYNOPSIS:
Defendants sought review of an order from the Court of Appeals of New York, which held that N.Y. Penal Law §§ 140.15(4), 120.80, authorized police officers to enter a private residence without a warrant and with force, if necessary, to make a routine felony arrest. Defendants contended that the statutes violated the constitutional prohibition against illegal searches and seizures.
OVERVIEW: Two cases on appeal challenged the constitutionality of N.Y. Penal Law §§ 140.15(4), 120.80. In the first case, police officers established probable cause against defendant in a murder case, and went to defendant's apartment to arrest him. Police officers entered without a warrant and found incriminating evidence in plain view that was admitted at defendant's trial. In the second case, police officers entered defendant's house to arrest him without a search warrant and found narcotics in the dresser.
HOLDING:
On appeal, the United States Supreme Court reversed and remanded the cases for further proceedings because the Fourth and Fourteenth Amendments prohibited 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 held that to be arrested in the home involved not only the invasion attendant to all arrests, but also an invasion of the sanctity of the home, which was too substantial, absent exigent circumstances, even when it was accomplished under statutory authority and when probable cause was present.
OUTCOME: The Court reversed and remanded the cases for further proceedings because the Fourth and Fourteenth Amendments prohibited the police from making warrantless and nonconsensual entry into suspects' homes in order to make routine felony arrests.
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445 U.S. 573
SYNOPSIS:
Defendants sought review of an order from the Court of Appeals of New York, which held that N.Y. Penal Law §§ 140.15(4), 120.80, authorized police officers to enter a private residence without a warrant and with force, if necessary, to make a routine felony arrest. Defendants contended that the statutes violated the constitutional prohibition against illegal searches and seizures.
OVERVIEW: Two cases on appeal challenged the constitutionality of N.Y. Penal Law §§ 140.15(4), 120.80. In the first case, police officers established probable cause against defendant in a murder case, and went to defendant's apartment to arrest him. Police officers entered without a warrant and found incriminating evidence in plain view that was admitted at defendant's trial. In the second case, police officers entered defendant's house to arrest him without a search warrant and found narcotics in the dresser.
HOLDING:
On appeal, the United States Supreme Court reversed and remanded the cases for further proceedings because the Fourth and Fourteenth Amendments prohibited 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 held that to be arrested in the home involved not only the invasion attendant to all arrests, but also an invasion of the sanctity of the home, which was too substantial, absent exigent circumstances, even when it was accomplished under statutory authority and when probable cause was present.
OUTCOME: The Court reversed and remanded the cases for further proceedings because the Fourth and Fourteenth Amendments prohibited the police from making warrantless and nonconsensual entry into suspects' homes in order to make routine felony arrests.
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Interested in learning how to get the top grades in your law school classes? Want to learn how to study smarter than your competition? Interested in transferring to a high ranked school?
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