Payton v. New York Case Notes

Payton v. New York

Case Overview

• Citation: 445 U.S. 573 (1979)
• Deals with the constitutionality of New York statutes authorizing police to enter a private residence without a warrant, using force if necessary, to make a routine felony arrest.
• The central issue is whether warrantless and nonconsensual entry into a suspect's home for a routine felony arrest violates the Fourth Amendment, which is applicable to the states via the Fourteenth Amendment.

Facts of the Cases

Payton's Case

• January 14, 1970: New York detectives developed probable cause to believe Theodore Payton murdered a gas station manager.
• January 15: Six officers went to Payton's apartment without a warrant to arrest him.
• They broke open the door after receiving no response.
• Payton was not there, but police found a .30-caliber shell casing in plain view, which was later used as evidence.
• Payton surrendered later and was indicted for murder.
• The trial judge ruled the warrantless entry was lawful under New York law and admitted the shell casing as evidence, citing exigent circumstances to justify the failure to announce their purpose.
• The prosecutor conceded that the warrantless search of the apartment was illegal and that all the seized evidence except the shell casing should be suppressed.

Riddick's Case

• March 14, 1974: Obie Riddick was arrested for two 1971 armed robberies.
• Victims identified him in June 1973, and police located his address in January 1974 but did not obtain a warrant.
• Detectives knocked on Riddick's door, and his son opened it. They saw Riddick in bed.
• Officers entered, arrested Riddick, and found narcotics and related paraphernalia in a chest of drawers near the bed.
• Riddick was indicted on narcotics charges.
• The trial judge ruled the warrantless entry was lawful under New York law, and the search was reasonable under Chimel v. California, $395 U.S. 752$.

New York Court of Appeals Decision

• The Court of Appeals affirmed both convictions in a single opinion, acknowledging the unsettled question of warrantless home arrests.
• The court distinguished between intrusions for searches and those for arrests, citing a greater governmental interest in arrests.
• They noted the historical acceptance of warrantless entries for felony arrests in English common law and American state practice.

Dissenting Opinion

• Three judges dissented, arguing that the Fourth Amendment requires a warrant for home entry to arrest unless exigent circumstances exist.
• They emphasized the greater invasion of privacy in an arrest than in a search for objects.
• They acknowledged the long-standing statutory authority for warrantless arrests but argued that historical practice does not justify violating constitutional rights and reasoned analysis.

Court's Reasoning

• The Court notes it granted probable jurisdiction to address the question, and called for reargument. $439 U.S. 1044$, $441 U.S. 930$
• The Fourth Amendment, applied to the States via the Fourteenth Amendment (Mapp v. Ohio, $367 U.S. 643$; Wolf v. Colorado, $338 U.S. 25$), prohibits warrantless and nonconsensual entry into a suspect's home for a routine felony arrest.
• The Court set aside the question of exigent circumstances, which they define as emergency or dangerous situations.
• The court is clear that they are only addressing entries into the home of the suspect being arrested, and not a third party's home.
• The Court states that in both Payton and Riddick, the police had probable cause to believe the respective suspect was home. The Court is not addressing situations were police enter without this probable cause and only address situations where the police did not have consent to make entry.
• The Fourth Amendment was designed to prevent the abuse of general warrants and condemns unreasonable searches or seizures without any warrant.
• The warrantless arrest of a person is a species of seizure required by the Fourth Amendment to be reasonable (Beck v. Ohio, $379 U.S. 89$).
• The physical entry of the home is the chief evil against which the Fourth Amendment is directed (United States v. United States District Court, $407 U.S. 297, 313$).
• Searches and seizures inside a home without a warrant are presumptively unreasonable.
• Objects such as weapons or contraband found in a public place may be seized by the police without a warrant.
• The distinction between a warrantless seizure in an open area and such a seizure on private premises was plainly stated in G. M. Leasing Corp. v. United States, $429 U. S. 338, 354$: "It is one thing to seize without a warrant property rest- ing in an open area or seizable by levy without an intru- sion into privacy, and it is quite another thing to effect a warrantless seizure of property, even that owned by a corporation, situated on private premises to which access is not otherwise available for the seizing officer."
• Judge Leventhal, in Dorman v. United States ($140 U. S. App. D. C. 313, 435 F. 2d 385 (1970)$), noted that freedom from intrusion into the home is the archetype of privacy protection secured by the Fourth Amendment.
• The Second Circuit has summarized its position: "To be arrested in the home involves not only the inva- sion attendant to all arrests but also an invasion of the sanctity of the home. This is simply too substantial an invasion to allow without a warrant, at least in the absence of exigent circumstances, even when it is accom- plished under statutory authority and when probable cause is clearly present."
• Differences in intrusiveness between entries to search and entries to arrest are merely ones of degree rather than kind; both involve breaching the entrance to an individual's home.
• In terms that apply equally to seizures of property and to seizures of persons, the Fourth Amendment has drawn a firm line at the entrance to the house. Absent exigent circumstances, that threshold may not reasonably be crossed without a warrant.
• New York cited United States v. Watson, $423 U. S. 411$, arguing that this case should have the same ruling. In regards to this point, the Court considered three reasons for the Watson holding:
  • The well-settled common-law rule that a warrantless arrest in a public place is valid if the arresting officer had probable cause to believe the suspect is a felon.
  • The clear consensus among the States adhering to that well-settled common-law rule.
  • The expression of the judgment of Congress that such an arrest is "reasonable."
• The Court concluded that the common-law rule on warrantless home arrests was not as clear as the rule on arrests in public places.
• A majority of the States that have taken a position on the question permit warrantless entry into the home to arrest even in the absence of exigent circumstances, but the current figures reflect a significant decline during the last decade in the number of States permitting warrantless entries for arrest.
• No congressional determination that warrantless entries into the home are