US Supreme Court Brigham City v. Stuart 05-502

Decision here.

5-22-05

   Another older decision, I like warrantless entry cases so...

   Police in Utah responded to a call of a loud party.  From outside the house, officers witnessed a physical fight between a drunk juvie and some adults in the kitchen.  An officer opened the door and announced his presence, but no one noticed.  So the police went into the house to deal with the fight.  Several people were arrested and charged with contributing to the delinquency of a minor.

   At trial, the court suppressed all evidence after the police entered the house, holding that the entry violated the Fourth Amendment.  The court held that the injury caused in the fight (the juvie punched one of the adults in the mouth, causing him to bleed) was insufficient to trigger the emergency aid exception, and also that after making entry the officers acted in an enforcement capacity rather than rendering aid.  And the trial court held that there were no exigent circumstances.

   The Supreme Court held that the police were confronted with ongoing violence within the house, and that satisfied the exigent circumstances requirement.  Given that people in the house were currently fighting, the Fourth Amendment does not require officers to wait until someone is badly hurt before they take action.  The Court also pointed out that an officer's subjective intentions are irrelevant to Fourth Amendment Analysis, so it didn't matter whether the officers intended to make arrests or patch up a nosebleed.  All that matters is whether or not the entry was objectively reasonable, and in this case is clearly was.

   The concurring opinion in this case is amusing to read.

US Supreme Court Illinois v. Caballes 03-923

Decided January 24, 2005.

   Caballes was stopped for speeding.  As soon as the traffic stop was made, another officer came to the scene of the stop with a K9.  When he got there, Cabelles' was in the first officer's car while the first officer was filling out a warning ticket.  The K9 handler had the dog sniff the outside of Caballes' car.  The dog alerted, and the officers searched the car for drugs.  They found marijuana (enough for a 12 year sentence).  The entire incident took 10 minutes.  Caballes appealed his conviction, and the Illinois Supreme Court held that the dog sniff converted his detention from a traffic stop to a drug investigation, and that there was no reasonable suspicion for a drug investigation.

   The US Supreme Court reversed the Illinois Supreme Court, holding that since the dog sniff did not prolong the traffic stop beyond the time required to complete the original purpose of the stop, no additional reasonable suspicion was required.  And since the court had previously held that dog sniffs for contraband do not invoke the fourth amendment, and since SCOTUS deferred to the trial court's judgment that the dog's alert was sufficient to establish probable cause, the evidence was admitted and the conviction affirmed.