Warden v. Hayden (1967)
United States Supreme Court
Author: P Mac Daddy

Procedure: After petitioner had been convicted in a Maryland state court of armed robbery upon evidence including items of his clothing seized during a search of his home. After unsuccessful state post-conviction proceedings, petitioner instituted the present habeas corpus proceeding in the United States District Court for the District of Maryland and was denied relief. The Court of Appeals for the Fourth Circuit reversed, holding that the clothing seized was improperly admitted in evidence because it had evidential value only.

Statement of the case: Hayden (D) contends that evidence was improperly admitted in his state trial when it should have been suppressed due to lack of search warrant. Other than that he has no complaints, except the fact that his cellmate keeps staring at his ass and making inappropriate gestures in his directions.

Facts: police upon information that a person suspected of an armed robbery had entered a house a few minutes before, gained a warrantless entry into the dwelling; whereby, the search revealed the D and the evidence that was subsequently used in his conviction. This evidence included a shotgun found in the bathroom of the dwelling, a small caliber handgun and clip and clothing resembling the robbers in the washing machine. This was a taxi robbery that netted $363 dollars, not bad considering that he’ll do an 8-10 year stretch for it, hope it was worth it!

Issue: Is a search warrant necessary to enter a house to search for a suspect that may have just been involved in an armed robbery, and to conduct any subsequent search if incidental to the arrest?

Holding: (Other than your balls) warrant is not necessary if the exigencies of the situation make that course imperative, and items which may relate to the crime can be seized. This is applicable to situations such as this one where police were following a suspected taxi armed robber into a private dwelling.

Reasoning: (Brennan) 1) Neither the entry without warrant to search for the robber, nor the search for him without warrant, was invalid, since under the circumstances of the case, the exigencies of the situation made that course imperative; (2) under the Fourth Amendment no distinction exists between merely evidentiary materials, which may not be seized, and those objects which may validly be seized, including the instrumentalities and fruits of crime, and contraband, and (3) the items of clothing were properly admitted in evidence. The fourth amendment allows intrusions upon privacy under these circumstances (exigent) and there is no viable reason to distinguished intrusions to secure mere evidence from intrusions to secure fruits, instrumentalities or contraband! (198)

(Remember to be a good Eskimo – never eat the yellow snow!)