US Supreme Court Warden v. Hayden 480

Decided May 29, 1967

   I looked this case up because it kept coming up in my research on hot pursuit.

   Hayden committed an armed robbery at a taxi company, and two taxi drivers followed him home.  They relayed his address to their dispatcher, who relayed it to the police, who showed up at Hayden's home within five minutes of him getting there.  They knocked, Hayden's wife answered the door, and she offered no objection when the police made entry to search for a robber.  They found Hayden pretending to be asleep in an upstairs bedroom.  They also found a gun in a nearby toilet tank, and in a washing machine they found the clothes the robber was wearing.

   The Supreme Court upheld the warrantless search, because "the exigencies of the situation made that course imperative... The Fourth Amendment does not require police officers to delay in the course of an investigation if to do so would gravely endanger their lives or the lives of others. Speed here was essential, and only a thorough search of the house for persons and weapons could have insured that Hayden was the only man present and that the police had control of all weapons which could be used against them or to effect an escape."

   So there's that.  The interesting thing is that this was only a minor part of the decision.  Most of the decision has to do with establishing the government's right to seize evidence that only has evidentiary value, rather than also being contraband or the instrumentality of a crime.  Apparently, we couldn't always do that.