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Payton v. New York | 445 U.S. 573 (1980)
Imagine you’re a police officer. You’ve tracked a suspect down to his home and have probable cause that he committed a murder. Are you allowed to enter the home and arrest the suspect without an arrest or search warrant? The United States Supreme Court addressed this very scenario in Payton versus New York.
In two separate New York cases, police officers developed probable cause that the suspects had committed serious felonies – a murder by Theodore Payton, and armed robberies by Obie Reddick. Without obtaining arrest warrants or search warrants, the officers entered the two men’s respective homes to arrest them. A New York statute authorized officers to enter a suspect’s home to arrest the suspect if the officers had probable cause that the suspect had committed a felony offense.
Once inside Payton’s home, officers saw a shell casing in plain view. Based on probable cause that the shell fit the murder weapon, the officers seized it and later offered it as evidence at Payton’s murder trial. At Reddick’s home, the officers looked in a drawer near where they arrested him as a search incident to his arrest. Inside the drawer, officers found illegal drugs. Reddick was charged with possessing the drugs.
Both Payton and Reddick moved to suppress the evidence seized by the officers, but the state trial courts denied the motions, and both men were convicted. On appeal, the Appellate Division of the New York Supreme Court affirmed the men’s convictions. The New York Court of Appeals granted review of their cases and consolidated their appeals in order to address the constitutionality of the state statute permitting a warrantless entry into a suspect’s home to make an arrest. That court upheld the statute and affirmed the lower courts’ judgments. Payton and Reddick sought review of their cases by the United States Supreme Court.
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