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Supreme Court Decision Update - Brigham City v. Stuart

supreme1.jpgToday’s Supreme Court case, Brighton City v. Stuart (PDF of the opinion) deals with search and seizure, and specifically, the “emergency aid doctrine,” which allows officers to enter a home without probable cause in the event of an emergency.

QuizLaw Analysis:The Supremes today decided to further erode the protections of the Fourth Amendment by expanding the emergency aid exception to basically include the threat of an emergency, in addition to actual emergencies. So in response to this, QuizLaw’s advice is to watch where you’re roughhousing in the future, lest the fuzz perceive an imminent emergency and seize your rainy-day stash.

The case involves one of those raucous 3 a.m. parties at a house in Brigham City, Utah. After police were called about the loudness, they arrived, walked down the driveway, and saw two juveniles getting hammered in the backyard. Entering into the yard, they also saw through a screen window and into the kitchen where four more juveniles and an adult were involved in an altercation. Specifically, one of the kids had punched the adult, causing him to spit blood into the sink. The officers entered the kitchen, whereupon the hoo-ha subsided, and the officers then arrested several of the adults, charging them with contributing to the delinquency of a minor and related offenses. Stuart, one of the arrested adults, filed a motion to suppress the evidence obtained after the officers entered the home, arguing it was not admissible because the warrantless entry violated the Fourth Amendment. The trial court, the Utah Court of Appeals, and the Utah Supreme Court all agreed, holding that the juvenile’s punch was insufficient to trigger the “emergency aid” exception to the Fourth Amendment.

The Supreme Court, however, disagreed. In a unanimous opinion written by Chief Justice Roberts, the Supremes held that the officers’ entry was “plainly reasonable under the circumstances.” They noted that, given the fracas going on when they arrived, the officers had an “objectively reasonable basis for believing both that the injured adult might need help and that the violence was just beginning.” Previously, the emergency aid doctrine had stated that police could only enter a home if they had an “objectively reasonable belief that an unconscious, semiconscious, or missing person feared injured or dead was in the home.” The money shot in this opinion, however, is how the Supremes relaxed that requirement, stating that “[n]othing in the Fourth Amendment required them to wait until another blow rendered someone unconscious, semiconscious, or worse before entering.” In other words, the emergency aid doctrine has unofficially been renamed “the threat of an emergency doctrine.”

Justice Stevens filed a several-page concurrence to the unanimous decision, to add his own thoughts to this “odd flyspeck of a case.” In particular, J.P. is a bit flummoxed about how this case actually got to the Supreme Court in the first place, and wants to affirm his earlier refusal to deny certiorari to this case (he obviously lost that fight, or we wouldn’t have this opinion today).