Tuesday, November 5, 2013

Brigham City, Utah v. Stuart case brief

Brigham City, Utah v. Stuart case brief summary
126 S. Ct. 1943 (2006)

Defendants' motion to suppress all evidence obtained after police officers entered a home where defendants were restraining a juvenile was granted based on the warrantless entry's violation of the Fourth Amendment. The Supreme Court of Utah affirmed. Certiorari was granted in light of differences among courts concerning the appropriate Fourth Amendmentstandard governing warrantless entry by law enforcement in an emergency situation.

At about 3 a.m., four police officers responded to a call regarding a loud party at a residence. Upon arriving at the house, they heard shouting from inside, and proceeded down the driveway to investigate. There, they observed two juveniles drinking beer in the backyard. They entered the backyard, and saw, through a screen door and windows, an altercation taking place in the kitchen of the home. According to the testimony of one of the officers, four adults were attempting, with some difficulty, to restrain a juvenile. The juvenile eventually broke free, swung a fist and struck one of the adults in the face. The officer testified that he observed the victim of the blow spitting blood into a nearby sink.

  • The court held that it did not matter whether the officers entered the kitchen to arrest defendants and gather evidence against them or to assist the injured and prevent further violence. 
  • The court also held that the officers had an objectively reasonable basis for believing both that the injured adult might need help and that the violence in the kitchen was just beginning. 
  • Nothing required them to wait until someone was "unconscious" or "semi-conscious" or worse before entering.
The judgment was reversed and the case was remanded for further proceedings.

Recommended Supplements for Criminal Procedure Criminal Procedure: Examples & Explanations, Sixth Edition
Emanuel Law Outline: Criminal Procedure

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