Payton v. New York Case Brief

Facts of the case

New York City police suspected Theodore Payton of murdering a gas station manager. The police forcibly entered Payton’s home thinking he was there (he was not) and found evidence connecting Payton to the crime, which was introduced at Payton’s trial. The police lacked an arrest warrant when they entered his home. However, they acted under a New York law allowing police to enter a private residence to make a felony arrest without a warrant. At trial, Payton unsuccessfully sought to suppress the evidence as the fruit of an illegal search. State courts upheld. In the companion case, victims identified Obie Riddick in June 1973 for robberies in 1971. Police learned of his whereabouts in 1974. Without a warrant, they knocked on his door, entered his residence and arrested him. A search for weapons revealed illegal drugs. He was indicted on narcotics charges but sought the suppression of the evidence based on a warrantless entry. The trial judge concluded that the entry was authorized by the New York law and that the search was therefore permissible. Riddick was convicted. The appeals court affirmed.

Why is the case important?

The Supreme Court of the Untied States (“Supreme Court”) consolidated two cases in this decision. The police entered the homes of the defendants, Theodore Payton (“Mr. Payton”) and Obie Riddick (“Mr. Riddick”)(the “defendants”), without a warrant and subsequently confiscated evidence found on the premises.

Question

Whether there is an illegal search and seizure when, without a warrant, police search a home during the course of an arrest and seize evidence where there is probable cause, but no exigent circumstances?

ANSWER

It is unconstitutional, under the Fourth Amendment of the Constitution, to search a home during an arrest when there is no arrest warrant and there are no exigent circumstances. The Supreme Court holds that the entrance to a person’s home is a critical point where constitutional safeguards are heightened. This is true even when probable cause exists or when there is statutory authority permitting the searches.

CONCLUSION

The Supreme Court of the United States reversed and remanded the cases for further proceedings. It held that the Fourth and Fourteenth Amendments prohibited the police from making a warrantless and nonconsensual entry into a suspect’s home in order to make a routine felony arrest. The Court further held that to be arrested in the home involved not only the invasion attendant to all arrests, but also an invasion of the sanctity of the home, which was too substantial, absent exigent circumstances, even when it was accomplished under statutory authority and when probable cause was present.

  • Advocates: William E. Hellerstein on behalf of the Appellants Peter L. Zimroth on behalf of the Appellee
  • Appellant: Payton
  • Appellee: New York
  • DECIDED BY:Burger Court
  • Location: –
Citation: 445 US 573 (1980)
ReArgued: Oct 9, 1979
Decided: Apr 15, 1980
Argued: Mar 26, 1979
Payton v. New York Case Brief