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Illinois v. McArthur:

US Supreme Court, 2001 (Breyer)

Author: P.V. Neff

 

  1. F: 4/97. Officers accompany Tera McArthur to her trailer to keep the peace while she moved out. On finishing she told the police that her husband (∆) had pot stashed under the couch. She and one officer sought a warrant while another stayed with ∆ on the porch, refusing to let him reenter the trailer unaccompanied. Once the warrant arrived the trailer was searched and pot was found.
  2. I: Was the pot found the fruit of an illegal seizure?
  3. P: trial court said yes and suppressed, appellate court affirmed, US Supreme Court reverses.
  4. H/R:
    1. The Court does not believe the seizure was per se unreasonable.

                                                               i.      It was limited in time and scope

                                                             ii.      It occurred under exigent circumstances

                                                            iii.      No significant intrusion into home itself

    1. Therefore, the Court balances the privacy-related and law enforcement-related concerns to determine if the intrusion was reasonable.
    2. The restriction was reasonable because:

                                                               i.      The police had PC to believe that there were drugs inside

                                                             ii.      The police had good reason to fear that if unrestrained ∆ would destroy the drugs

                                                            iii.      The police made reasonable effort to reconcile law enforcement and privacy needs by waiting for the warrant but not letting ∆ go in alone.

                                                           iv.      The restraint was limited in time

    1. ∆ looks to Welsh, where it was held unreasonable to enter the ∆’s house to obtain evidence that might be destroyed (blood alcohol level). This case is distinguishable because:

                                                               i.      the evidence here is jailable

                                                             ii.      the restriction here was less serious

  1. Dissent: (Stevens):
    1. The governmental interest in prosecuting this relatively insignificant crime is so slight that it does not outweigh the sanctity of the ordinary citizen’s home.