Arizona DUI & Criminal Defense Attorney Blog
In a unanimous decision coming from the Supreme Court of the United States, the Court held that a police officer’s pursuit of a fleeing misdemeanor suspect does not always qualify as an exigent or demanding circumstance that would otherwise justify a police officer’s warrantless entry into a home. This decision strengthens Fourth Amendment protections for individuals throughout the country by limiting, to a certain extent, the special circumstances that allow an officer to enter a home without a warrant.
The Facts of the Case
After a highway patrol officer observed loud music coming from a parked car, and the driver of the car honking the horn multiple times despite there being no other vehicles around, the officer decided to follow the vehicle once it began moving. After following the vehicle for several blocks, the officer turned on his overhead lights, but the driver of the vehicle failed to pull over. The driver turned into his driveway and pulled into his garage. The officer interrupted the closing garage door and asked the driver if he had noticed that the officer turned on his overhead lights. The driver replied that he had not, and was charged with two vehicle code misdemeanors.
In the trial court, the defendant (the driver) filed a motion to suppress the evidence obtained in the garage. During the suppression hearing, the prosecutor argued that the defendant committed a misdemeanor when he failed to stop the vehicle once the officer turned on his overhead lights and that the officer had probable cause to arrest the defendant as a result. The prosecutor further argued that “exigent circumstances” justified the officer’s warrantless entry into the defendant’s garage. The trial court denied the defendant’s motion to suppress, and the appellate court affirmed the trial court’s denial, ultimately leading to the defendant’s conviction. The defendant filed a civil lawsuit asking the court to overturn his suspended license, and this court found the defendant’s arrest to be unlawful since the officer’s warrantless entry into the defendant’s garage was only based on the defendant playing loud music and honking his horn a few times. The defendant eventually appealed to the Supreme Court of the United States.
The Court’s Decision
In the Court’s majority opinion, the Court explained that ordinarily, police officers are required to have a warrant before entering someone’s home. However, there are specific circumstances or exceptions to the warrant requirement, and one of those circumstances is the “exigency circumstance.” The “exigency circumstance” is an exception to the warrant requirement that allows an officer to enter a home without a warrant if an officer must act to prevent imminent injury, the destruction of evidence, or a felony suspect’s escape. The Court further explained that an “exigent circumstance” is not always or categorically created just because a misdemeanor suspect is fleeing. While a police officer’s hot pursuit of a felony suspect does categorically create an exception to the warrant requirement, an officer’s pursuit of a misdemeanor suspect does not create this exigency circumstance required for a warrantless home entry to be justified under this exception. Here, the defendant was suspected of committing a misdemeanor and not a felony, so the officer’s warrantless entry into the defendant’s garage was not justified. The Supreme Court Justices unanimously decided in favor of the defendant.
Have You Been Arrested for a Crime in Arizona?
If you have been arrested for a crime in Arizona, contact the Law Office of James E. Novak. Attorney Novak is dedicated to using his decades of experience to assist his clients and help them navigate the complex laws. Whether it involves an Arizona misdemeanor crime, felony offenses, or warrant issues, Attorney Novak is ready to speak to you about your case. Call the Law Office of James E. Novak at 480-413-1499 today to discuss your rights and remedies if you face Arizona criminal charges.