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Payton v. New York

Citations: 63 L. Ed. 2d 639; 100 S. Ct. 1371; 445 U.S. 573; 1980 U.S. LEXIS 13Docket: 78-5420

Court: Supreme Court of the United States; April 15, 1980; Federal Supreme Court; Federal Appellate Court

Narrative Opinion Summary

The Supreme Court case of Payton v. New York scrutinized the constitutionality of New York statutes allowing police to enter private residences without a warrant to arrest individuals for routine felonies. The case consolidated two appeals where police, with probable cause but without warrants, entered homes to arrest the appellants, leading to a legal challenge. The New York courts originally upheld the warrantless entries, citing state law. However, the Supreme Court reversed these decisions, holding that the Fourth Amendment, applied to the states through the Fourteenth Amendment, prohibits warrantless and nonconsensual home entries for routine felony arrests absent exigent circumstances. This decision highlighted the significant privacy invasion associated with home arrests compared to public arrests and underscored the need for a warrant to preserve the sanctity of the home. The Court's ruling clarified that arrest warrants based on probable cause permit limited home entry only when there is a belief that the suspect is present. The decision resolved conflicting lower court rulings and reinforced the constitutional protections against unreasonable searches and seizures, emphasizing the historical importance of home privacy.

Legal Issues Addressed

Distinction Between Public and Home Arrests

Application: The Court distinguished between public arrests, where warrantless actions may be justified, and home arrests, where historical common law favored warrant requirements.

Reasoning: It distinguished between public arrests, where warrantless actions may be justified, and home arrests, where historical common law favored warrant requirements.

Exigent Circumstances Exception

Application: The ruling specified that in the absence of exigent circumstances, a warrant is required for home entry to effectuate an arrest.

Reasoning: The Court emphasized that the sanctity of the home represents a significant invasion that warrants protection, requiring a warrant in the absence of exigent circumstances.

Fourth Amendment Protections in Home Arrests

Application: The Supreme Court held that warrantless and nonconsensual entries into a suspect's home for routine felony arrests are prohibited under the Fourth Amendment, emphasizing the sanctity of the home.

Reasoning: The Supreme Court held that the Fourth Amendment, applicable to the states via the Fourteenth Amendment, prohibits warrantless and nonconsensual entries into a suspect's home for routine felony arrests.

Probable Cause and Arrest Warrants

Application: An arrest warrant based on probable cause allows limited entry into a suspect's residence only when there is reason to believe the suspect is present.

Reasoning: The ruling reversed the lower courts' decisions, clarifying that an arrest warrant based on probable cause allows limited entry into a suspect's residence only when there is reason to believe the suspect is present.