Sunday, November 3, 2013

Warden v. Hayden case brief

Warden v. Hayden case brief summary
387 U.S. 294 (1967)

Petitioner warden sought review of an order from the United States Court of Appeals for the Fourth Circuit granting habeas corpus relief to respondent inmate after the inmate was convicted of armed robbery.

The inmate was convicted of armed robbery. Items of his clothing, including a cap, jacket, and trousers, were seized during a search of his home and were admitted into evidence without objection. After unsuccessful state court proceedings, the lower court granted habeas corpus relief to the inmate, finding that the clothing was improperly admitted into evidence because the items had evidential value only and were not subject to seizure.

  • On appeal by the warden, the Supreme Court found that neither the entry of the inmate's home nor the search for him without a warrant was invalid. 
  • Under the circumstances of the case, the exigencies of the situation made that course imperative. 
  • The Court further found that the seizure of clothing occurred prior to or immediately contemporaneous with the inmate's arrest, as part of an effort to find a suspected felon, armed, within the house into which he had run only minutes before the police arrived.
  • Finally, the Court found that the seized clothing matched the description of those worn by the robber and the police could have reasonably believed that the items would aid in the identification of the culprit.


The Court reversed the order granting habeas corpus relief to the inmate.

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

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