Sunday, January 13, 2019

Payton v. New York case brief

Payton v. New York case brief summary

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.


Facts:
•The police had probable cause to believe that Payton had murdered the manager of a gas station. There was music playing from inside but no answers to the knocks so police knocked his door down without a warrant
•They seized a shell casting that was submitted for evidence at his trial. He was not there but was later turned into police and is moving to remove the evidence obtained in his app

 Issue: whether the shell casting can be used against him in trial- but he has to stand trial no matter what

Analysis:
Warrantless searches inside a home are presumably unreasonable
Warrantless searches in public are permitted if there is probable cause
They are comparing warrantless search with probable cause in public vs. in a home
Drayton and Draper were not arrested in their home
“A man’s home is his castle”

•It is unreasonable for the police to enter a home without a warrant for the purpose of arresting the owner. •As a result, the warrantless entry into Payton’s home, the warrantless entry and arrest in Riddick’s home, and the accompanying searches and seizure, are a clear violation of the Fourth Amendment right to privacy and are unconstitutional.
•It's not just a piece of paper!
•It’s that they did not convince a neutral third party that he committed a crime and they had probable cause 

DISSENT: they met all of the requirements -- they had probable cause that he committed a felony, they knocked and announced, and it was in the day time!


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