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.
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 suspects 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 Amendments knock-and-announce rule.