Brigham City v. Stuart (full text)
U.S. Supreme Court
Brigham City v. Stuart, No. 05-502 (2006).
Decided May 22, 2006
Issue: 4th Amendment; Warrantless Entry
into a Home
Holding: Police may enter a home without a
warrant when they have an objectively reasonable basis for
believing that an occupant is seriously injured or imminently
threatened with such injury.
Summary:
In this non-OWI case, the Court addressed the legality of a
warrantless entry into a home. Police responded to a complaint of
a loud, late night party at a residence. When they arrived at the
house, they heard shouting from inside and proceeded into the
driveway to investigate. The police saw two juveniles drinking
beer in the backyard. They entered the backyard and observed a
fight in the kitchen of the home. Four adults were attempting to
restrain a juvenile. The juvenile broke free and struck one of the
adults in the face causing him to bleed. The other adults
continued their attempt to restrain the juvenile. An officer
opened the screen door and announced his presence but nobody
noticed. The officer entered the kitchen and the altercation
ceased. The officers arrested the adults and charged them with
contributing to the delinquency of a minor, disorderly conduct, and
intoxication.
The defendants filed a motion to suppress evidence obtained
after the officers entered the home, arguing that the warrantless
entry violated the Fourth Amendment. The respondents did not
dispute the principle that an officer may enter a home without a
warrant to render emergency assistance. Instead, the respondents
argued that, in this instance, the officers' entry was
unreasonable.
First, the defendants argued that the officers were more
interested in making arrests than quelling violence. In response,
the Court noted its unwillingness "to entertain Fourth Amendment
challenges based on the actual motivations of individual officers."
Whren v. United States, 517 U.S. 806, 813 (1996).
Here, the officers' subjective motivation was irrelevant to the
reasonableness of the entry.
The defendants next argued that their conduct was not
serious enough to justify the officers' intrusion into the home.
They cited
Welsh v. Wisconsin which held that the gravity of
the underlying offense is an important factor in determining if
exigent circumstances exist. 466. U.S. 740, 753 (1984). The
Court distinguished Welsh because in that
case the "only potential emergency" was the need to preserve
evidence of intoxication in a civil forfeiture violation - an
exigency that was held insufficient to justify entry into the
suspect's home. In contrast, here the "officers were confronted
with ongoing violence occurring within the home." Under these
circumstances, the officers' entry was held to be reasonable. The
Court noted that "nothing in the Fourth Amendment required them to
wait until another blow rendered someone "unconscious" or
"semi-conscious" or worse before entering.
Finally, the Court noted that the manner of entry was
reasonable and did not violate the Fourth Amendment's
knock-and-announce rule.