Kentucky v. King Case Brief: Supreme Court on Exigent Circumstances and Warrantless Entry

Case Brief: Kentucky v. King

Court: Supreme Court of the United States
Citation: 563 U.S. 452 (2011)
Decided: May 16, 2011

Facts:

Police officers in Lexington, Kentucky, set up a controlled buy of crack cocaine. After observing the suspect (later identified as Hollis King) entering an apartment complex, they pursued him into a breezeway. The officers heard a door shut and detected a strong odor of marijuana emanating from one of the apartments. Believing the suspect had entered this apartment, the officers knocked loudly and announced their presence. They heard movement inside, which they interpreted as the occupants possibly destroying evidence. The officers forcibly entered the apartment, finding King and others with marijuana and cocaine. King moved to suppress the evidence, arguing the warrantless entry violated the Fourth Amendment.

Issues:

1. Does the exigent circumstances rule apply when police, by knocking on the door and announcing their presence, cause the occupants to attempt to destroy evidence?
2. Was the warrantless entry into King's apartment justified under the Fourth Amendment?

Holding:

The Supreme Court held that the exigent circumstances rule applies as long as the police did not create the exigency by engaging or threatening to engage in conduct that violates the Fourth Amendment. In this case, the officers' conduct of knocking on the door and announcing their presence was not in itself a violation of the Fourth Amendment, making the warrantless entry justified.

Legal Reasoning:

• Exigent Circumstances: The Court reiterated that exigent circumstances, such as the imminent destruction of evidence, can justify a warrantless entry if the police do not create the exigency by violating or threatening to violate the Fourth Amendment.
• Police Conduct: The Court found that the officers did not engage in any wrongdoing by knocking on the door and announcing their presence. The decision to enter was based on the sounds of movement inside, which could reasonably be interpreted as an attempt to destroy evidence.
• Fourth Amendment Considerations: The Court clarified that lawful police action that leads to the creation of exigent circumstances does not violate the Fourth Amendment, provided the police action itself is not unconstitutional.

Conclusion:

The Supreme Court reversed the Kentucky Supreme Court's decision, holding that the police officers' warrantless entry was justified under the exigent circumstances rule, as their conduct leading up to the entry did not violate the Fourth Amendment.

List of Cases Cited

1. Mincey v. Arizona, 437 U.S. 385 (1978) - Recognized that warrantless searches are justified in certain exigent circumstances.
2. Brigham City v. Stuart, 547 U.S. 398 (2006) - Reiterated the principle that police may enter a home without a warrant to render emergency assistance to an injured occupant or to protect an occupant from imminent injury.
3. Michigan v. Fisher, 558 U.S. 45 (2009) - Applied the exigent circumstances doctrine in the context of a warrantless entry when police were responding to a potential emergency situation.

Similar Cases

1. Warden v. Hayden, 387 U.S. 294 (1967) - Upheld the validity of a warrantless search in hot pursuit of a fleeing felon.
2. Kentucky v. King, 563 U.S. 452 (2011) - Applied the exigent circumstances rule to justify warrantless entry when police did not create the exigency through unconstitutional conduct.