Brigham City v. Stuart
Encyclopedia
Brigham City v. Stuart, 547 U.S. 398 (2006), was a case decided by the Supreme Court of the United States
involving the exigent circumstances exception to the Fourth Amendment
's warrant
requirement. The Court ruled that police may enter a home without a warrant if they have an objectively reasonable basis for believing that an occupant is or is about to be seriously injured.
The case involved the arrest of four adults seen restraining a juvenile, who punched one of the adults who was restraining him. The trial court granted the defendants' motion to dismiss, arguing that the warrantless entry was not supported by exigent circumstance
s; the Utah Court of Appeals
and Utah Supreme Court
both affirmed the trial court's ruling. However, the U.S. Supreme Court reversed and remanded the case on May 22, 2006.
Police officers were dispatched to a loud house party. Upon going to the front door the officers determined that knocking would not be productive and then made their way down the driveway alongside the house to investigate. Through a slat fence they saw two juveniles consuming alcoholic beverage
s and entered the backyard, having probable cause to do so. While in the backyard the police officers saw an altercation taking place inside the house, which appeared to be four adults restraining a juvenile. At one point, the juvenile broke free and struck one of the occupants of the residence in the nose with his hand.
Two officers opened the screen door and "hollered" to identify themselves, but were unnoticed by the occupants. After entering the house, one officer shouted again to identify himself, this time alerting the occupants. The occupants then became upset at the presence of the officers in the residence without permission. The officers arrested the adults and charged them with contributing to the delinquency of a minor, disorderly conduct
, and intoxication. The defendants filed a motion to suppress with the trial court. The trial court sided with the defendants, and the city twice appealed to the Utah Court of Appeals and the Utah Supreme Court, which both affirmed the trial court's ruling.
. Justice John Paul Stevens
delivered a separate concurring opinion.
The court found that "the officers had an objectively reasonable basis for believing both that the injured adult might need help and that the violence in the kitchen was just beginning."
Also, the Court ruled that once the officers announced their presence they were free to enter the house to deal with the tumult as it would be pointless to stand at the door waiting for a response while people brawled inside.
Supreme Court of the United States
The Supreme Court of the United States is the highest court in the United States. It has ultimate appellate jurisdiction over all state and federal courts, and original jurisdiction over a small range of cases...
involving the exigent circumstances exception to the Fourth Amendment
Fourth Amendment to the United States Constitution
The Fourth Amendment to the United States Constitution is the part of the Bill of Rights which guards against unreasonable searches and seizures, along with requiring any warrant to be judicially sanctioned and supported by probable cause...
's warrant
Warrant (law)
Most often, the term warrant refers to a specific type of authorization; a writ issued by a competent officer, usually a judge or magistrate, which permits an otherwise illegal act that would violate individual rights and affords the person executing the writ protection from damages if the act is...
requirement. The Court ruled that police may enter a home without a warrant if they have an objectively reasonable basis for believing that an occupant is or is about to be seriously injured.
The case involved the arrest of four adults seen restraining a juvenile, who punched one of the adults who was restraining him. The trial court granted the defendants' motion to dismiss, arguing that the warrantless entry was not supported by exigent circumstance
Exigent circumstance
An exigent circumstance, in the American law of criminal procedure, allows law enforcement to enter a structure without a warrant, or if they have a "knock and announce" warrant, without knocking and waiting for refusal under certain circumstances...
s; the Utah Court of Appeals
Utah Court of Appeals
The Utah Court of Appeals is the intermediate-level appellate court for the state of Utah. It began operations in 1987.-Jurisdiction:The court's jurisdiction is complementary to that of the Utah Supreme Court. The Court of Appeals hears all appeals from the Juvenile and District Courts, except...
and Utah Supreme Court
Utah Supreme Court
The Utah Supreme Court is the supreme court of the state of Utah, USA. It has final authority of interpretation of the Utah Constitution. The Utah Supreme Court is composed of five members: a chief justice, an associate chief justice, and three justices. All justices are appointed by the governor...
both affirmed the trial court's ruling. However, the U.S. Supreme Court reversed and remanded the case on May 22, 2006.
Background of the case
On July 23, 2001, at about 3:00 AM, four Brigham CityBrigham City, Utah
Brigham City is a city in Box Elder County, Utah, United States. The population was 17,899 at the 2010 census. It is the county seat of Box Elder County. It lies on the western slope of the Wellsville Mountains, a branch of the Wasatch Range at the western terminus of Box Elder Canyon...
Police officers were dispatched to a loud house party. Upon going to the front door the officers determined that knocking would not be productive and then made their way down the driveway alongside the house to investigate. Through a slat fence they saw two juveniles consuming alcoholic beverage
Alcoholic beverage
An alcoholic beverage is a drink containing ethanol, commonly known as alcohol. Alcoholic beverages are divided into three general classes: beers, wines, and spirits. They are legally consumed in most countries, and over 100 countries have laws regulating their production, sale, and consumption...
s and entered the backyard, having probable cause to do so. While in the backyard the police officers saw an altercation taking place inside the house, which appeared to be four adults restraining a juvenile. At one point, the juvenile broke free and struck one of the occupants of the residence in the nose with his hand.
Two officers opened the screen door and "hollered" to identify themselves, but were unnoticed by the occupants. After entering the house, one officer shouted again to identify himself, this time alerting the occupants. The occupants then became upset at the presence of the officers in the residence without permission. The officers arrested the adults and charged them with contributing to the delinquency of a minor, disorderly conduct
Disorderly conduct
Disorderly conduct is a criminal charge in most jurisdictions in the United States. Typically, disorderly conduct makes it a crime to be drunk in public, to "disturb the peace", or to loiter in certain areas. Many types of unruly conduct may fit the definition of disorderly conduct, as such...
, and intoxication. The defendants filed a motion to suppress with the trial court. The trial court sided with the defendants, and the city twice appealed to the Utah Court of Appeals and the Utah Supreme Court, which both affirmed the trial court's ruling.
The court's decision
The Supreme Court reversed the decision of the Utah Supreme Court, in a unanimous opinion delivered by Chief Justice John RobertsJohn Roberts
John Glover Roberts, Jr. is the 17th and current Chief Justice of the United States. He has served since 2005, having been nominated by President George W. Bush after the death of Chief Justice William Rehnquist...
. Justice John Paul Stevens
John Paul Stevens
John Paul Stevens served as an Associate Justice of the Supreme Court of the United States from December 19, 1975 until his retirement on June 29, 2010. At the time of his retirement, he was the oldest member of the Court and the third-longest serving justice in the Court's history...
delivered a separate concurring opinion.
Exigency
The Court ruled that the officers' warrantless entry into the home was justified under the emergency aid exception to getting a warrant because their entry "was plainly reasonable under the circumstances." In ruling the officers' entry was supported by exigency, the Court cited Mincey v. Arizona, 437 U. S. 385, 393–394 (1978):- "[W]arrants are generally required to search a person’s home or his person unless 'the exigencies of the situation' make the needs of law enforcement so compelling that the warrantless search is objectively reasonable under the Fourth Amendment." ... One exigency obviating the requirement of a warrant is the need to assist persons who are seriously injured or threatened with such injury. ... Accordingly, law enforcement officers may enter a home without a warrant to render emergency assistance to an injured occupant or to protect an occupant from imminent injury. Mincey, supra, at 392; see also Georgia v. RandolphGeorgia v. RandolphGeorgia v. Randolph, 547 U.S. 103 , is a case wherein the U.S. Supreme Court held that without a search warrant, police had no constitutional right to search a house where one resident consents to the search while another resident objects. The Court distinguished this case from the "co-occupant...
, 547
The court found that "the officers had an objectively reasonable basis for believing both that the injured adult might need help and that the violence in the kitchen was just beginning."
'Knock and announce' Rule
The Court found that "the manner of the officers’ entry was also reasonable." The court found that after seeing the punch, one officer opened the screen door to the kitchen and yelled in "police." Upon nobody hearing him, he stepped into the kitchen and then announced himself again, which prompted the tumult to subside. The Court ruled that:- ...the officer’s announcement of his presence was at least equivalent to a knock on the screen door. Indeed, it was probably the only option that had even a chance of rising above the din. Under these circumstances, there was no violation of the Fourth Amendment’s knock-and-announce rule.
Also, the Court ruled that once the officers announced their presence they were free to enter the house to deal with the tumult as it would be pointless to stand at the door waiting for a response while people brawled inside.