Vale v. Louisiana Case Brief

Why is the case important?

Police arrested appellant Donald Vale on the street outside his home and then went into his home nearby and conducted a search, recovering additional narcotics in the process.

Facts of the case

New Orleans police officers had a warrant to arrest Donald J. Vale on narcotics charges. While staking out Vale’s home, the officers saw Vale come out of the house and do what they thought was a drug deal. The officers arrested Vale outside his home and told him they were going to search the house. The officers did not have a search warrant. During the search, the officers found narcotics in a back bedroom. This evidence was admitted at Vale’s trial where he was convicted. The Louisiana Supreme Court affirmed his conviction. The court rejected Vale’s argument that the narcotics evidence was the product of an unreasonable search and seizure.

Question

Is a search of a home allowed to be considered valid under the Fourth and Fourteenth Amendment as being incident to an arrest if the arrest did not take place within the home?

Answer

No. Reverse the judgment and remand the case.
If a search of a house is to be upheld as incident to an arrest, the arrest must take place inside the house. This arrest did not, so the search fails under the Fourth Amendment, and introducing the fruits into evidence was thus error.

Conclusion

The Court held that the warrantless search of defendant’s house violated the Fourth Amendment, and hence, the evidence introduced at trial should have been declared inadmissible. According to the Court, an arrest on the street outside of defendant’s dwelling did not justify a warrantless search of defendant’s dwelling. The Court averred that if a search of a house was to be upheld as incident to an arrest, the arrest must take place inside the house. Even if the officers had probable cause to conduct the search, the Court held that the existence of such an exceptional situation as to justify a search without a warrant was not shown.

  • Case Brief: 1970
  • Appellant: Donald J. Vale
  • Appellee: Louisiana
  • Decided by: Burger Court

Citation: 399 US 30 (1970)
Argued: Mar 4 – 5, 1970
Decided: Jun 22, 1970
Granted Oct 13, 1969