Automobiles - Exigent Circumstances

Question 1

US v. Chadwick—Moveable Containers

Answer 1

The U.S. Supreme Court, in a 7-2 decision, affirmed the Court of Appeals’ ruling and held that the warrantless search of the locked footlocker violated the Fourth Amendment. Writing for the majority, Justice Potter Stewart explained that the search of the footlocker could not be justified under the automobile exception established in Carroll v. United States because, unlike vehicles, footlockers are not inherently mobile and do not present the same exigent circumstances that vehicles do. Furthermore, the Court found that the defendants had a reasonable expectation of privacy in the contents of the footlocker, which was protected by the Fourth Amendment.

Question 2

California v. Acevedo—Search; The Car and Whole Kitchen Sink

Answer 2

The U.S. Supreme Court, in a 6-3 decision, reversed the California Court of Appeal’s ruling and held that the warrantless search of the closed container in Acevedo’s car was permissible under the Fourth Amendment. Writing for the majority, Justice Byron White reasoned that the automobile exception, first established in Carroll v. United States, permits warrantless searches of vehicles when there is probable cause to believe the vehicle contains contraband or evidence of a crime. In place of that uncertain distinction, the Court adopted a single rule: “The police may search an automobile and the containers within it where they have probable cause to believe contraband or evidence is contained.”

Question 3

Exigent Circumstances Doctrine—not a brightline

Answer 3

The Exigent Circumstances Doctrine is an exception to the Fourth Amendment’s warrant requirement, which protects individuals from unreasonable searches and seizures. Under this doctrine, law enforcement officers may conduct a warrantless search or make a warrantless entry into a home or other private property when exigent circumstances exist. Exigent circumstances are emergency situations that require immediate action to protect public safety, prevent the destruction of evidence, or apprehend a fleeing suspect.

Question 4

Brigham City v. Stuart—Exigent Circumstance - Worldstar!!!

Answer 4

The U.S. Supreme Court, in a unanimous decision, reversed the lower courts’ rulings and held that the warrantless entry into the home was permissible under the Fourth Amendment. Writing for the Court, Chief Justice John Roberts reasoned that the emergency aid exception allows law enforcement officers to enter a home without a warrant when they have an objectively reasonable basis for believing that someone inside is in need of immediate aid. In this case, the officers’ observations of the ongoing fight and their concern for the safety of the individual being assaulted provided sufficient justification for the warrantless entry. Officers have a duty to prevent violence and restore order, and waiting until another blow rendered someone unconscious or worse before entering was not required by the Fourth Amendment. The Court emphasized that a police officer’s role is not simply to render first aid to casualties, but to prevent violence and restore order.

Question 5

Dorman 6 Factors - Determining Exigent Circumstance

Answer 5

1. The gravity of the offense: A more serious offense may justify a warrantless entry, while a minor offense may not.
2. Whether the suspect is reasonably believed to be armed: If the police have reason to believe the suspect is armed and dangerous, a warrantless entry may be more justifiable.
3. Clear showing of probable cause: The police must have strong evidence that the suspect committed the crime.
4. Strong reason to believe that the suspect is in the dwelling: The police must have a reasonable basis for believing the suspect is present in the home.
5. The likelihood of escape if not swiftly apprehended: If there is a significant risk that the suspect may escape or pose a threat to others if not immediately apprehended, a warrantless entry may be justified.
6. Whether the entry is peaceable: A violent or disruptive entry may weigh against the constitutionality of a warrantless arrest, while a more peaceable entry may be more justifiable.

Question 6

Kentucky v. King

Answer 6

The U.S. Supreme Court, in an 8-1 decision, reversed the Kentucky Supreme Court’s ruling and held that the warrantless entry into the apartment was permissible under the Fourth Amendment. Writing for the majority, Justice Samuel Alito reasoned that the exigent circumstances exception permits law enforcement officers to enter a home without a warrant when they have an objectively reasonable belief that evidence is being destroyed. The Court further held that police may rely on this exception even if their actions, such as knocking and announcing their presence, led to the destruction of evidence, as long as their actions were lawful and did not create the exigency through a threat or other unlawful means.

The exigent circumstances rule applies when the police do not gain entry to premises by means of an actual or threatened violation of the Fourth Amendment. This holding provides ample protection for the privacy rights that the Amendment protects