Case Facts
Payton v. New York – 445 U.S. 573 (1980) involved two cases. In the first case, New York City police raided Theodore Payton’s residence to arrest him as a key suspect in the killing of a gas station manager. The police knocked on Payton’s door and later broke in after waiting without any response. Although there was nobody in the house, some evidence linking the suspect to the murder case was seized by the police during the house inspection. Payton sought to suppress this evidence in court on the grounds that the police inspection was not warranted. The trial judge declined to grant Payton’s plea, asserting that warrantless house inspection was recognized by the New York Statute under certain circumstances (Rabasca, 2012).
In the second case, New York City police raided the residence of Obie Riddick in 1974 and arrested him as a robbery suspect. Although the police did not have a warrant to inspect Riddick’s house, they inspected it and seized some narcotic drugs. Riddick was sued for being in possession of illicit drugs but he sought to suppress the evidence on the grounds that the inspection was not warranted. The trial judge declined to grant his plea. Payton and Riddick also lost appeals and referred the matter to the Supreme Court (Rabasca, 2012).
Case Issue
The Supreme Court was to determine whether the New York Statute that recognized unwarranted inspections and arrests contravened the Fourth Amendment or not (Rabasca, 2012).
Legal Reasoning
The appellants claimed that the warrantless inspections infringed on their privacy as founded in the Fourth Amendment. However, the police asserted that they acted with probable cause as guided by the New York Statute (Rabasca, 2012). In the dissenting opinion by Justice Stevens, the Fourth Amendment was used to overturn the findings of the court of appeal. Stevens said that the findings of the lower courts were only based on the fact that the New York Statute recognized such inspections. He claimed that in the absence of exigent circumstances, the warrantless intrusion was illegal even if there was probable cause. According to Stevens, a probable cause should lead to the acquisition of warrants before inspections and arrests are done. Since the lower courts did not consider exigent circumstances, there was no way they could have arrived at the decision to convict Payton and Riddick.
Stevens quoted Mapp v. Ohio – 367 U.S. 643 (1961) case in which the Supreme Court asserted that evidence obtained in contravention of the Fourth Amendment by unwarranted inspection could not be accepted as evidence (Long, 2006 & Zotti, 2005). In another case, Wolf v. Colorado, 338 U.S. 25 (1949), although the supreme court did not rule in favour of exclusion of evidence obtained through unwarranted intrusion, it agreed that such exclusion would be an effective way to realize the intentions of the Fourth Amendment (Long, 2006 & Zotti, 2005). According to Justice Stevens, the Fourth Amendment was brought into being to protect fundamental rights and any interpretation or legislation that encourages abuse of such rights contravenes the amendment. Stevens’ opinion seems to be influenced by his strong belief in protection of right to privacy.
Held
The Supreme Court held by 6 to 3 that unwarranted arrests and house inspections amounted to gross violation of the Fourth Amendment.
Importance of the Ruling
The ruling by the Supreme Court means that the New York Statute that permits unwarranted home inspection is illegal. The ruling also gives guidelines on how to enforce arrests and inspections without compromising the suspects’ right to privacy as established under the Fourth Amendment. In addition, the ruling contributes to common law by giving precedence to be used in determining similar cases in future.
References
Long, C. (2006). Mapp v. Ohio: Guarding Against Unreasonable Searches and Seizures. Kansas: University Press of Kansas. Mapp v. Ohio – 367 U.S. 643 (1961).
Payton v. New York – 445 U.S. 573 (1980).
Rabasca, A. M. (2012). Payton V. New York: Is reason to believe probable cause or a lesser standard? Journal of Law, 5(6):1-6 Wolf v. Colorado, 338 U.S. 25 (1949).
Zotti, P. H. Machado (2005). Injustice for All: Mapp vs. Ohio and the Fourth Amendment. New York: Peter Lang.