This Utah case concerns police intervention in a violent, early-morning altercation at a house party, resulting in several arrests. The United States Supreme Court agreed to hear the case after the Utah state court system ruled at all levels that evidence was properly suppressed because the police did not have a warrant to enter the house. The Supreme Court strongly disagreed, saying the officers’ conduct was clearly reasonable under the circumstances, fully justifying their entering the home without a warrant under the Fourth Amendment of the United States Constitution. Brigham City, Utah v. Stuart (— S.Ct. —, 2006 WL 1374566, 2006 Daily Journal D.A.R. 6156, U.S.Utah, May 22, 2006)
Facts
Police in Brigham City, Utah, responded to a 3 a.m. call on July 23, 2000, about a loud party. When the four police officers arrived at the house in question, they heard shouting inside, proceeded down the driveway, and saw two juveniles drinking beer in the backyard. Entering the yard, they saw — through a screen door and windows — an altercation in the kitchen between four adults and a juvenile, who punched one of the adults, causing him to spit blood in a sink. An officer opened the screen door and announced the officers’ presence, but went “unnoticed amid the tumult,” according to the Utah Supreme Court opinion. The officer then entered the kitchen and again “cried out,” whereupon “the altercation gradually subsided.” The officers arrested those involved in the altercation, charging them with contributing to the delinquency of a minor, intoxication and disorderly conduct.
The trial court granted the defendants’ motion to suppress all evidence obtained after the officer entered the home on grounds that the warrentless entry violated the 4th Amendment. That judgment was affirmed by the Utah Court of Appeals and the Utah Supreme Court. The United States Supreme Court overruled the Utah courts.
Decision
In a strongly worded opinion written by Chief Justice John Roberts, the nation’s highest court ruled police may enter a home without a warrant when they have an “objectively reasonable basis” for believing that an occupant is seriously injured or “imminently threatened” with such injury. Roberts noted that the Court agreed to hear the case “in light of differences among state courts and the Courts of Appeals concerning the appropriate Fourth Amendment standard governing warrantless entry by law enforcement in an emergency situation (see In re Sealed Case 96-3167, 153 F. 3d759, 766 (CADC 1998).
“We think the officers’ entry here was plainly reasonable under the circumstances,” Roberts wrote. “The officers were responding, at 3 o’clock in the morning, to complaints about a loud party. As they approached the house, they could hear from within ‘an altercation occurring, some kind of a fight’. . . In these circumstances, 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. Nothing in the Fourth Amendment required them to wait until another blow rendered someone ‘unconscious’ or ‘semi-conscious’ or worse before entering.” Noting that the role of a peace officer includes prevention of violence and restoring order, Robert said their role is “not simply rendering first aid to casualties; an officer is not like a boxing or hockey referee, poised to stop a bout only if it becomes too one-sided.”
Accordingly, the Court reversed the judgment of the Utah Supreme Court.
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