Citation. Payton v. New York, 445 U.S. 573, 100 S. Ct. 1371, 63 L. Ed. 2d 639, 1980 U.S. LEXIS 13 (U.S. Apr. 15, 1980)
Brief Fact Summary. The Supreme Court of the Untied States (“Supreme Court”) consolidated two cases in this decision. The police entered the homes of the defendants, Theodore Payton (“Mr. Payton”) and Obie Riddick (“Mr. Riddick”)(the “defendants”), without a warrant and subsequently confiscated evidence found on the premises. Facts.
Synopsis of Rule of Law. The Fourth and Fourteenth Amendments of the United States Constitution (“Constitution”) prohibit warrantless entries for searches of homes, absent exigent circumstances, even when there is probable cause.
New York police believed that Mr. Payton was responsible for murdering a gas station manager two days prior to his arrest. Six officers went to Mr. Payton’s apartment and, when no one answered their knock, forcibly entered. Upon entering, they saw a shell casing in plain view that would later be admitted into evidence.
New York police arrested Mr. Riddick in 1974, three years after the two robberies that he was charged for were committed. Again, the police entered his home without a warrant, and they found narcotics in a drawer two feet from where Mr. Riddick was arrested. Issue.
Whether there is an illegal search and seizure when, without a warrant, police search a home during the course of an arrest and seize evidence where there is probable cause, but no exigent circumstances?