Illinois v. McArthur Case Brief

Why is the case important?

The police refused to allow an individual to enter his home after being informed by his wife that there was dope in the home.

Facts of the case

“In 1997, Tera McArthur asked two police officers to accompany her to her trailer, where she lived with her husband, Charles McArthur, so that they could keep the peace while she removed her belongings. While at the trailer, Tera alerted the officers, Assistant Chief John Love and Officer Richard Skidis, that her husband had marijuana hidden under the couch. Love then asked Charles for permission to search the trailer. Permission was denied and Love sent Officer Skidis with Tera to get a search warrant. Love told Charles he could not reenter his trailer, unless a police officer accompanied him. Afterwards, Love stood just inside the door to observe Charles when he went into the trailer. About two hours later, a search warrant was obtained. Subsequently, a search of the trailer transpired and officers found drug paraphernalia and marijuana. Charles McArthur was arrested. At trial, McArthur moved to suppress the drug paraphernalia and marijuana on the ground that they were the “”fruit”” of an unlawful police seizure, namely, the refusal to let him reenter the trailer unaccompanied, which would have permitted him, he said, to “”have destroyed the marijuana.”” The trial court granted the motion. The Appellate Court of Illinois affirmed and the Illinois Supreme Court denied the state’s petition for leave to appeal.”

Question

Whether the police violated an individual’s rights when they refused to allow him to enter his home for two hours so as to obtain a search warrant?

Answer

No. The court began by observing that there are certain situations where a warrant is not required. When faced with special law enforcement needs, diminished expectations of privacy, minimal intrusions, or the like, the Court has found that certain general, or individual, circumstances may render a warrantless search or seizure reasonable.
The search here was reasonable for four reasons. First, the police had probable cause to believe that Mr. McArthur’s trailer home contained evidence of a crime and contraband, namely, unlawful drugs. Second, the police had good reason to fear that, unless restrained, Mr. McArthur would destroy the drugs before they could return with a warrant. Third, the police made reasonable efforts to reconcile their law enforcement needs with the demands of personal privacy. Finally, the police imposed the restraint for a limited period of time, namely, two hours.
Further, the court observed temporarily keeping a person from entering his home, a consequence whenever police stop a person on the street, is considerably less intrusive than police entry into the home itself in order to make a warrantless arrest or conduct a search.
Additionally, the need to preserve evidence of a ‘jailable’ offense was sufficiently urgent or pressing to justify the restriction upon entry that the police imposed.

Conclusion

The United States Supreme Court found that the warrantless seizure was not per se unreasonable, since it involved exigent circumstances, and the restraint at issue was tailored, avoiding significant intrusion into the home itself. Consequently, the court balanced the privacy-related and law enforcement-related concerns to determine if the intrusion was reasonable. The court concluded that the restriction at issue was reasonable, and hence lawful. Police had probable cause to believe defendant’s home contained unlawful drugs, and had good reason to fear that, unless restrained, defendant would destroy the drugs before they could return with a warrant. Also, police made reasonable efforts to reconcile their law enforcement needs with the demands of personal privacy, and they imposed the restraint for a limited period of time, two hours. Given the nature of the intrusion and the law enforcement interest at stake, the brief seizure of the premises was permissible. Moreover, the court found significant support in its case law, and was not persuaded by the countervailing considerations raised by the parties and lower courts.

  • Case Brief: 2001
  • Petitioner: Illinois
  • Respondent: McArthur
  • Decided by: Rehnquist Court

Citation: 531 US 326 (2001)
Argued: Nov 1, 2000
Decided: Feb 20, 2001