Payton v. New York, 445 U.S. 573 (1980)

In January of 1970, after two days of investigation, New York detectives had assembled sufficient evidence to establish probable cause to believe that Theodore Payton had murdered the manager of a gas station a few days earlier. On January 15, 1970, six officers arrived at Payton’s home with the intent to arrest him without a warrant. Although there were significant signs and noise indicating that someone was in the residence, there was no answer to the officers’ knock on the door. Emergency assistance arrived a short time later, and the officers used crowbars to enter the residence. No one was home, but in plain view was a shell casing that was seized and later admitted into evidence against Payton at his trial. Payton later surrendered and moved to suppress the casing. At the time in New York, there existed a statute that allowed police officers to enter a private residence without a search warrant and with force, if necessary, to make a routine felony arrest.
The trial judge held that the warrantless entry into Payton’s home was allowed under the New York Code of Criminal Procedure. Furthermore, the judge held that the shell casing seized in plain view was properly seized. The rationale behind the judge’s decision was that he found exigent circumstances justified the officers’ failure to announce their presence before entering the residence. However, the judge failed to decide whether the circumstances justified the failure to obtain a warrant, and rather concluded that the state statute supported the entry.
The issue before the Supreme Court was whether the New York statute was a violation of constitutional protections. The Court decided that the statute was, in fact, unconstitutional. The Fourth Amendment, made applicable to the states through the Fourteenth Amendment, prohibits police from making a warrantless and nonconsensual entry into a suspect’s home to make a felony arrest. The Court’s opinion pointed out that it was arguable that the warrantless entry to arrest Payton might have been justified by exigent circumstances. However, none of the New York courts relied on such justification. In fact, the New York statute circumvented the justification and treated such arrests as routine arrests.
Physical entry of the home, and the violation of the right to be secure in one’s own house, is the chief evil against which the wording Fourth Amendment is directed. Entries into a house without a warrant are presumptively unreasonable. The protection of the Fourth Amendment of an individual’s privacy is clearly in regard to the dimension of one’s individual home. A person can retreat into his or her home and maintain a reasonable expectation of privacy. Without any exigent circumstances, a person is safe in his or her home, and the person’s interest in the sanctity of his or her home outweighs governmental interests. In this case, there existed no exigent circumstances. Rather, there existed only a state statute that circumvented the requirement of exigent circumstances.