Posted May 22, 2006

 Brigham City, Utah v. Stuart (2006) 547 US ___ ,  WL 1374566

 US Supreme Court Rules that Police May Lawfully Enter A Residence Where  a Fistfight is in Progress

           Brigham City Police Officers were called to a residential disturbance at 3:00 a.m. Through a window from outside the house, they saw scuffling and one person land a punch to another's face that caused bleeding. One officer stepped inside the screen door and announced the police presence, but the shouting occupants did not notice. Officers then went in and stopped the fight, arresting several occupants for misdemeanor offenses.

           The defendants successfully moved to suppress evidence as the fruit of an unlawful entry. The Utah Supreme Court ruled that the fighting did not amount to a sufficient exigency to justify warrantless entry, and believed that the officers' subjective intentions to make arrests, rather than to render aid, invalidated their entry.

           On the prosecutor's appeal, the US Supreme Court unanimously reversed the Utah courts. First, the court repeated its many previous holdings that Fourth Amendment issues are objectively determined, without regard to the individual police officers' subjective motivations. Second, the court held that preventing violence and injury is a legitimate exigency that excuses the warrant requirement. Third, the court said that stepping inside and announcing police presence was "at least equivalent to a knock on the screen door."