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Payton v. New York, 445 U.S. 573 (1980)
3
Description of Events
Issues
Violated?
do you have one?
January 14, 1970, six New York Police Officers entered Theodore Payton's house based on probable cause (PC) that he was the suspect in a murder that occurred two days prior involving a gas station manager.
The Police forcibly entered Payton's home, thinking Payton was home at the time, and discovered he was not present.
Upon leaving the residence, the Police saw a .30 caliber shell casing in "Plain View," and seized it for evidence.
Payton later turned himself in and was indicted on murder charges.
ARGUMENT
- Warrantless entry (NY Statute authorizing police officer's to enter a private residence to make a felony arrest without a warrant.)
- 4th Amendment- search and seizure without a warrant and no exigent circumstances.
- 14th Amendment- "...No State shall make or enforce any law which shall abridge the privilages or immunities of citizens of the United States..."
- The defense argued that the 4th Amendment and 14th Amendment of the U.S. Constitution were violated.
- NY Statutes 140.15 and 120.80, at that time, allowed police officers to enter into a private residence to make an arrest without a warrant if they had probable cause that the suspect was present, or make entry by exigent circumstances.
- The petitioner argued that no search warrant was needed because NY Statute allowed that type of entry. This was a "common practice" among many U.S. States that allowed such an entry into a private residence.
- The argument was made that the NY Statute violated Payton's Constitutional right to be secure in his home and free from warrantless searches.
Crossing the threshold?
What this all means for law enforcement
VIDEO EXAMPLE
What question does this case raise?
Does New York statute authorizing warrantless arrests and searches violate the Fourth Amendment prohibition against unreasonable searches and seizures?
Conclusion
- Cannot enter a dwelling unless a warrant has been issued.
- Exigent circumstances exist (life in danger, suspect escape, destruction of evidence)
- Cannot cross the threshold if only PC for arrest exists and has no consent to enter the dwelling
What does this case establish for law enforcement? (video)
Key points to remember:
Opinion of the Court
Argued
March 26, 1979
Re-argued
October 9, 1979
Decided
April 15, 1980
In a 6 to 3 decision, the U.S. Supreme Court held that the 4th Amendment applied to the states by the 14th Amendment which prohibits a warrantless and nonconsensual entry into a person's home in order to make a routine felony arrest.
The main issue at point was that warrantless arrests and searches violated the core of the 4th Amendment's protection of privacy in one's dwelling.
4th and14th Amendment
Search/Arrest warrant
Threshold
THE END
By Recruits Kyle Strand and Shane Stevie
Learning Objectives
- Learn what police actions caused Payton v. NY
- Be able to identify and explain what Constitutional Rights were violated as a result of this case
- Be able to explain what limitations Law Enforcement has in regards to entering a dwelling without a warrant
QUESTIONS?