RESPONDENT: Charles W. Stuart, et al.
LOCATION: Board of Immigration Appeals
DOCKET NO.: 05-502
DECIDED BY: Roberts Court (2006-2009)
LOWER COURT: Utah Supreme Court
CITATION: 547 US 398 (2006)
GRANTED: Jan 06, 2006
ARGUED: Apr 24, 2006
DECIDED: May 22, 2006
Jeffrey S. Gray - argued the cause for Petitioner
Michael Patrick Studebaker - argued the cause for Respondents
Paul J. McNulty - argued the cause for Petitioner
Facts of the case
Responding to a complaint about a loud party, police arrived at a house where they saw minors drinking alcohol outside and heard shouting inside. As they approached the house, they saw a fight through the window involving a juvenile and four adults, one of whom was punched hard enough to make him spit blood. The officers announced their presence, but the people fighting did not hear them so they entered the home. They arrested the men for contributing to the delinquency of a minor and other related offenses. The trial court judge, however, refused to allow the evidence collected after the police entered the home because it was a warrantless search in violation of the Fourth Amendment. On appeal, the government argued that the search was covered by the "emergency aid doctrine" because the officers were responding to seeing the man be punched. The Supreme Court of Utah disagreed, however, ruling that the doctrine only applies when there is an unconscious, semiconscious, or missing person who is feared injured or dead. The Court also gave weight to the fact that the officers acted exclusively in a law enforcement capacity, not to assist the injured man.
What objectively reasonable level of concern is necessary to trigger the emergency aid exception to the Fourth Amendment's warrant requirement?
Media for Brigham City v. StuartAudio Transcription for Oral Argument - April 24, 2006 in Brigham City v. Stuart
Audio Transcription for Opinion Announcement - May 22, 2006 in Brigham City v. Stuart
John G. Roberts, Jr.:
I have the opinion in 05-502 Brigham City versus Stuart.
At about 3 o’ clock in the morning, four Brigham City Utah police officers responded to a call regarding a loud party at a residence.
When they arrived at the house, they heard shouting from inside coming from the back of the house.
They proceeded down the driveway to investigate.
From the backyard, they could see into the home’s kitchen through a screen door and windows.
There was an altercation taking place.
Four adults were trying to restrain a juvenile.
The juvenile broke free and punched one of the adults in the face.
The victim went to spit blood into a sink while the other adults continued trying to subdue the juvenile.
One of the officers opened the screen door and yelled in ‘Police’, but the ruckus from the fight was too loud, nobody heard him.
So he stepped into the kitchen and again cried out.
As people gradually became aware that the police were on the scene, the altercation subsided.
The officers then arrested several of the adults for Disorderly Conduct, Intoxication and Contributing to the Delinquency of a Minor.
The Trial Court excluded all evidence obtained after the officers entered the home on the ground that the officer’s entry violated the Fourth Amendment.
On appeal, the Supreme Court of Utah also concluded that the officer’s entry was improper.
The Court said that the injury caused by the juvenile’s punch was not serious enough to allow the officers to enter.
This is because, the Court said, it could not have led a reasonable officer to believe that an unconscious, semiconscious, or missing person feared injured or dead was in the home; we granted review.
The Fourth Amendment generally prohibits officers from entering a private home without a warrant; but there are certain exceptions.
For example, officers may enter without a warrant to fight a fire or when they are in pursuit of a fleeing felon.
If the situation confronting officers is serious enough to make immediate entry reasonable, the Fourth Amendment will allow it.
One such situation is the need to protect life or avoid imminent serious injury.
The defendants in this case don’t dispute this, but make two arguments why the officers still could not enter.
First, they claimed that the officers here were more interested in making arrests than in quelling violence.
They want us to consider the officers’ subjective motivation for entering the home.
Our cases reject this approach.
An action is reasonable under The Fourth Amendment as long as the circumstances, viewed objectively justify the action.
The defendants also argue that their conduct was not serious enough to justify the officers’ entry.
We think however, 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.
The Fourth Amendment did not require the officers to wait until another blow rendered someone unconscious or semiconscious or worse before entering.
Police officer is not like a boxing referee who only steps in to stop a fight when it becomes too one-sided.