Payton vs New York - Case Study Example

 Payton vs New York---- Legal Case Facts of the case Legal case reference: 445 U.S. 573 (1980) Appellants......................Theodore Payton and Obie Riddick Appellee........................ State of New York, U.S.A. Lawyer for Appellee.......Peter. L. Zimroth Lawyer for Appellants.... William. E. Hellerstein Appellants’ claim That it is the violation of the fourth amendment of New York Statute, if an officer is authorized to enter a home without a warrant for making an arrest. Justices for the court Harry. A. Blackmun, John Paul Stevens (writing for the court), Lewis. F. Powell, Jr., Potter Stewart, Thurgood Marshall and William. J. Brennan, Jr.. Chief Justice, Warren E. Burger presided over the proceedings as the the case progressed. Dissenting Justices Byron R. White, J, Warren E. Burger, C.J. , William H Rehnquist, J. Court decision Briefly summarized, the court decision states that the fourth amendment prohibits entry without warrant, of an officer into any one’s home. The details of the case and the decision there-of shall be explained in the following pages........................(1) Place..................... Washington, D.C. Argument dates.....March 26 and October 9, 1979 Date of decision...... April 15, 1980.........(2) APPEAL FROM THE COURT OF APPEALS OF NEW YORK. No. 78-5420---Payton vs. New York, together with No. 78-5421, on appeal from same court, argued on March 26 and reargued on Oct. 9, 1979. The appeals refer to the fourth amendment of New York Statute as they challenge its constitutional authority to permit the entry of police officers into a private residence, without a valid warrant, and with the idea of making a felony arrest. The entry of the officer will be with the police force, if necessary. In both the appeals, the police officer had entered the appellant’s residence without the consent of any occupant and arrested the appellant on felony charges. In each of these cases, New York trial Judge held that the evidences seized upon these entries could not be suppressed, while the honored judge held that the New York Statutes authorized these entries without warrants. However, the New York court of Appeals treated both these as cases of routine arrests that allowed ample time to obtain an arrest warrant. Hence, this court ultimately affirmed the convictions of both the appellants, as being a single opinion of the court.................(3) Holding A non-consensual entry without any warrant by a police person into a residence of any suspect with the intention of making a felony arrest is not permitted under the fourth amendment, as made applicable to the states by the fourteenth amendment. These have been described as summarized below. Fourth amendment has recognized the chief evil of unauthorized entry. Hence, the wordings of this amendment are directed against this evil practice only. It has held the sanctity of the home being supreme, while dealing with such arrests with out any exigent circumstances. Although there may be sufficient cause for the felony arrest to be done in the residence itself, the amendment has drawn a firm line in making such arrests in the absence of exigent circumstances. The court has cited that the reasons for making arrests at a public place cannot apply to the invasion of a private home without any warrant. (Case No.423 US 411, United States vs. Watson) has been cited as the public place arrest reference. To make the rules clear with regard to common laws for arrests at public or private places, the fourth amendment laid out the requirement of a warrant for making the felony arrest at the private residence. Although many of the states have permitted these arrests without any exigent circumstance, a declining trend to the same is evident now. Comparing the cases with that of Watson, there are no statute references to indicate the determination of the congress for terming the warrant-less entry as “reasonable”. The forth amendment proposes that the arrest warrant that has been founded on a probable cause gives the limited authority to the law enforcing staff for entering the premises, where suspect lives, with the sufficient reason to believe that the suspect can be inside.....(4) Concurring opinions Justice Brennen, Stewart, Marshall, Blackmun and Powell had a concurring opinion on the case in support of the decision held by the court. Justice White, J. had a dissenting view on the case and it was supported by the other dissenting views from Burger, C.J. and Rehnquist, J . While arguing the case for both the appellants, William E. Hellerstein was assisted for briefing by David A. Lewis. However, Peter L. Zimroth had a battery of assistants on the briefs that included Brain Rosner, Vivian Burger, John J. Santucci and Henry J. Steinglass, to argue for the appellee on both the dates. While delivering the opinion of the court, Mr. Justice Stevens gave the appeal details This was followed by the reference of US vs. Watson case (423 US 411), where the midday public arrest was upheld by the court. However, Steven J. also referred to the Supreme Court of Florida rejecting such constitutional attack, as was the done for the present case, earlier, in the appeals court, New York. The justice further listed that ten other states have held it unconstitutional to make unwarranted arrests at home, unless supported by certain special circumstances.(445 US 573, 575/76)..............(5) Referring to the last term of arguments about the jurisdiction of these appeals (439 US 1044), Steven, J. informed that the reargument date was set for this term (441 US 930). According to Steven, J, the earlier New York Court of appeals decision was reversed. It further held that the fourth amendment to the United States Constitution made available to the states by the fourteenth amendment, does not permit the police personnel to make an entry into the private residence of a suspect, without a warrant and consent of the occupants, for making a felony arrest......................(6) Explaining on the case records, Steven, J. informed that New York detectives had collected sufficient evidence, on Jan 14th. 1970, to believe that Theodore Payton had murdered the manager of a gas station, about a couple of days back. On visiting Payton’s apartment in Bronx on Jan 15, 1970 at 7.30 A.M., with the purpose of arresting him without a warrant, none of the house occupants opened the door, although the lights and music was on inside the home. After summoning the emergency assistance, the door was broken and after entering the house, they did not found anyone there. However, a 30-caliber shell casing was seized from the house and it was submitted as evidence at Payton’s murder trial. However, later Payton surrendered to the police and was tried for the murder. In another similar case, Obie Riddick was arrested on March 14, 1974, for two armed robberies conducted in the year 1971. Same day, at noon detectives with three other officers visited his home at Queens and arrested him without any warrant. They also seized narcotics from his drawers and he was later tried on narcotics charges. The New York Court of Appeals held affirmation of convictions of both Payton and Riddick (45 N Y 2nd 300 and 380 N E 2nd 224, 1978), in a single opinion. While majority supported the holding by noting the “apparent historical acceptance” of making entries without any warrants for felony arrests, in practice at many American States and in English Common law, three members held dissenting views, as they believed that the constitution requires a warrant to enter a home and making the arrests there...............(7) However, Stevens, J. delivered the final verdict after the reargument of the cases on Oct 9, 1979. While finding the earlier affirmations unpersuasive, the final verdict of the court declared that according to the fourth amendment proposal, an arrest warrant gives a limited authority for the officer to enter the private home of the suspect with reasonable cause to believe that the suspect is within the residence at that time. Mr. Justice Stevens further noted that since no arrest warrants were obtained in any of these cases, hence the earlier order should be reversed and cases be remanded, for further proceedings, to New York Court of Appeals, in consistence with this judgment. While concurring with the opinion of the court, Justice Blackmun mentioned the proceedings of the Watson case (423 US 411, 1976), where he was in favor of the Court’s opinion for an warrant-less arrest. However, the honored justice was of the opinion, that in present cases, the suspect’s interest in sanctity of his home has more weight than the interests of the Govt.. He therefore stressed that both the verdicts are judicially correct, while referring to Watson’s arrest as a “public arrest” and Payton’s arrest as ‘private home arrest”.........(8) Dissenting Views The Chief Justice Berger joined Mr.Justice White and Mr. Justice Rehnquest in dissenting with the opinion of the court. Justice White mentioned that the warrant-less arrest, in the absence of any exigent circumstances, for a dangerous felony has been denied by this court. However, as per Justice White, there is little support to this in the common English Law or in the text and history of fourth amendment to the constitution. He further opined that the stringent rule concerning the intrusiveness of home entries and arrests (445 US 573, 604) has no evidential support from the common law or the fourth amendment statute.....................(9) Importance of the case The decision of the court in both these cases has been a landmark for various states to follow. In most of the further court rulings, this case decision has been referred and upheld, that influenced the individual court rulings as well. Conclusion Both these cases have their relevance in the legal history of United Sates of America. While the definition of “exigent circumstances” is debatable, the simplest method to determine the need for a warrant-less entry and arrest for felony charges, is the time factor. If the case is very sensitive and important, then the detectives working on it may not have enough time to get a valid warrant. This may include the circumstances where there is every possibility of the suspect getting away from the town or city or even fleeing the country. However, when there is sufficient time and evidence to believe that the suspect can be arrested with a valid search and arrest warrant, the sanctity of home and its privacy should be respected fully. With this consideration, the honorable court has reversed the earlier affirmation, after the case was again argued on Oct 9, 1979. Hence, the final ruling of the honorable Court is justified and legally correct, as it upholds the constitutionality of the fourth amendment statute. This has also upheld the American tradition of respecting the basic family values and private freedom of all residents. ______________________________________________ BIBLIOGRAPHY In-text citation references (1)"Payton v. New York." Great American Court Cases. Ed. Mark F. Mikula and L. Mpho Mabunda. Gale Cengage, 1999. eNotes.com. 2006. 28 Mar, 2009 http://www.enotes.com/american-court-cases/ payton-v-new-york (2)The Oyez Project, Payton v. New York , 445 U.S. 573 (1980) available at: (http://oyez.org/cases/1970-1979/1978/1978_78_5420) (last visited Monday, March 28th, 2009). (3)Supreme Court of United States, Theodore Payton vs. New York State http://dunster.harvard.edu/law/lawschoolforme/SampleCases/Payton.pdf accessed on 28th March, 2009 (4)US Supreme Court Center> US Supreme Court Cases & Opinions> Volume 445 > PAYTON V. NEW YORK, 445 U. S. 573 (1980) http://supreme.justia.com/us/445/573/, accessed on 28th March, 2009 (5)U.S. Supreme Court PAYTON v. NEW YORK, 445 U.S. 573 (1980) http://caselaw.lp.findlaw.com/scripts/getcase.pl?court=US&vol=445&invol=573, paaragraphs 1-27, accessed on 27th Marh,2009 (6)U.S. Supreme Court PAYTON v. NEW YORK, 445 U.S. 573 (1980) http://caselaw.lp.findlaw.com/scripts/getcase.pl?court=US&vol=445&invol=573, paragraphs 31-39 accessed on 27th Marh,2009 (7)U.S. Supreme Court PAYTON v. NEW YORK, 445 U.S. 573 (1980) http://caselaw.lp.findlaw.com/scripts/getcase.pl?court=US&vol=445&invol=573 paragraphs 41-47 accessed on 27th Marh,2009 (8)U.S. Supreme Court PAYTON v. NEW YORK, 445 U.S. 573 (1980) http://caselaw.lp.findlaw.com/scripts/getcase.pl?court=US&vol=445&invol=573, paragraph 77-87 accessed on 27th Marh,2009 (9)U.S. Supreme Court PAYTON v. NEW YORK, 445 U.S. 573 (1980) http://caselaw.lp.findlaw.com/scripts/getcase.pl?court=US&vol=445&invol=573 paragraph 99-115 accessed on 27th Marh,2009 Sources used Payton v. New York - Further Readings U.S. Supreme Court PAYTON v. NEW YORK, 445 U.S. 573 (1980) http://caselaw.lp.findlaw.com/scripts/getcase.pl?court=US&vol=445&invol=573, paragraph 14 U.S. Supreme Court PAYTON v. NEW YORK, 445 U.S. 573 (1980) http://caselaw.lp.findlaw.com/scripts/getcase.pl?court=US&vol=445&invol=573, paragraph 25 )"Payton v. New York." Great American Court Cases. Ed. Mark F. Mikula and L. Mpho Mabunda. Gale Cengage, 1999. http://www.enotes.com/american-court-cases/ payton-v-new-york The Oyez Project, Payton v. New York , 445 U.S. 573 (1980) available at: (http://oyez.org/cases/1970-1979/1978/1978_78_5420) Supreme Court of United States, Theodore Payton vs. New York State http://dunster.harvard.edu/law/lawschoolforme/SampleCases/Payton.pdf US Supreme Court Center> US Supreme Court Cases & Opinions> Volume 445 > PAYTON V. NEW YORK, 445 U. S. 573 (1980) http://supreme.justia.com/us/445/573/ Molly, PAYTON V. NEW YORK, 445 U. S. 573 http://www.4lawschool.com/criminal/payton2.htm, Read More