Payton v. New York: Supreme Court Case, Arguments, Impact

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In Payton v. New York (1980), the Supreme Court found that warrantless entry into a private home to make a felony arrest violated the Fourth Amendment of the U.S. Constitution. New York state statutes could not authorize officers to illegally enter a person's home.

Key Takeaways: Payton v. New York (1980)

  • In Payton v. New York, the Supreme Court analyzed whether warrantless entry into a private home to make a felony arrest violated the Fourth Amendment of the U.S. Constitution.
  • The majority opinion found that entering a home without a search warrant violated the Fourth Amendment except in "exigent circumstances."
  • In other words, the situation must be such that a reasonable person would consider entering the home to be the only way to prevent violence or destruction of evidence.

Facts of the Case

In 1970, detectives from the New York City police department found probable cause linking Theodore Payton to the murder of a manager at a gas station. At 7:30 a.m. the officers approached Payton's apartment in the Bronx. They knocked but received no response. They did not have a warrant to search Payton's home. After about 30 minutes of waiting for Payton to open the door, the officers called an emergency response team and used a crowbar to force open the door to the apartment. Payton was not inside. Instead, an officer found a .30 caliber shell casing which was used as evidence at Payton's trial.

At his trial, Payton's attorney moved to have the evidence of the shell casing suppressed because it was gathered during an illegal search. The trial court judge ruled that the evidence could be admitted because New York State Code of Criminal Procedure allowed for warrantless and forcible entry. Evidence could be seized if it was in plain view. Payton appealed the decision and the case proceeded upwards through the courts. The U.S. Supreme Court decided to take on the case after several similar cases also appeared before the justices as a result of New York State statutes.

Constitutional Issues

Can police officers enter and search a home without a warrant to make a felony arrest? Can a New York state statute permit an unconstitutional search and seizure of evidence under the Fourth Amendment?

The Arguments

Attorneys on behalf of Payton argued that the officers violated Payton's Fourth Amendment rights when they entered and searched his home without a valid search warrant. The felony arrest warrant did not give the officers grounds to force open Payton's door and seize evidence, even though the evidence was in plain view. The officers had plenty of time to get a separate search warrant for Payton's home, the attorneys argued. The shell casing was obtained during an illegal search when Payton was not present in the home and therefore could not be used as evidence in court.

Attorneys representing the state of New York argued that the officers were following the New York Code of Criminal Procedure when they entered and seized evidence in plain view in Payton's home. The state of New York relied on the case United States v. Watson for analysis. In that case, the Supreme Court upheld a common law rule that officers may conduct a warrantless arrest in a public place if they had probable cause to believe the arrestee had committed a felony. The rule in U.S. v. Watson was crafted out of English common law tradition. Under common law at the time the Fourth Amendment was written, officers could enter a home to make a felony arrest. Therefore, the attorneys argued, the Fourth Amendment should allow officers to enter Payton's home to arrest him.

Majority Opinion

Justice John Paul Stevens delivered the majority opinion. In a 6-3 decision, the Court focused on the language and intent of the Fourth Amendment, incorporated to the states through the Fourteenth Amendment. The Fourth Amendment prevents police from “making a non-consensual entry into the suspect’s home in order to make a routine felony arrest.” The officers in Payton’s case had no reason to believe Payton was home. There were no noises coming from inside the apartment. If Payton had been home, the officers might have needed to enter the apartment to properly arrest him, but there was no reason to believe someone was in the apartment.

The majority opinion was careful to draw a distinction between the situation in Payton’s case and a situation where exigent circumstances might have been present. Exigent or special circumstances may provide officers with a valid reason to enter the home. Without such circumstances, officers cannot enter the home without a search warrant. In ruling this way, the Court placed the determination for probable cause in the hands of judges rather than officers and put an individual’s Fourth Amendment right above police intuition.

Dissenting Opinion

Justice Byron R. White, Chief Justice Warren E. Burger, and Justice William H. Rehnquist dissented on the basis that common law allowed the officers to enter Payton's home. They looked to common law tradition at the time the Fourth Amendment was ratified. English common law required that officers arresting someone for a felony knock, announce their presence, approach the house during the day, and have probable cause to believe the subject of the arrest warrant is inside the house.

Based on these requirements, the dissenting Justices wrote that English officers regularly entered homes to make felony arrests. Justice White explained:

"Today's decision ignores the carefully crafted restrictions on the common law power of arrest entry, and thereby overestimates the dangers inherent in that practice."

Impact

The Payton ruling built upon past decisions including U.S. v. Chimel and U.S. v. Watson. In U.S. v. Watson (1976), the court ruled that an officer could arrest a person in a public space without a felony arrest warrant if they had probable cause. Payton prevented this rule from extending into the home. The case drew a hard line at the front door in order to uphold Fourth Amendment protections against warrantless home intrusions.

Sources

  • Payton v. New York, 445 U.S. 573 (1980).
  • United States v. Watson, 423 U.S. 411 (1976).