Payton v. New York
Citation and Court
445 U.S. 573 (1980) — Supreme Court of the United States
Facts
New York police officers, acting under a state statute authorizing warrantless home entries to make felony arrests, entered Payton’s apartment without a warrant to arrest him for murder. He was not home, but officers seized a shell casing in plain view that was later used against him. A companion case, Riddick v. New York, involved a warrantless home arrest that was effected without exigent circumstances.
Issue
Does the Fourth Amendment prohibit police from making a warrantless, nonconsensual entry into a suspect’s home to make a routine felony arrest?
Holding
Yes; absent exigent circumstances or consent, the Fourth Amendment prohibits warrantless entries into a home to arrest its occupant, even for a felony.
Rule / Doctrine
An arrest warrant is required to enter a suspect’s own home to effectuate an arrest. The home receives the highest Fourth Amendment protection; physical entry of the home is the chief evil against which that amendment is directed.
Significance
Payton establishes that the home is the most protected Fourth Amendment space and that a warrant (or recognized exception such as exigent circumstances or consent) is required before police may cross the threshold to arrest. It remains the leading authority requiring an arrest warrant for in-home arrests.