Vale v. Louisiana:   
United States Supreme Court, 1970. 

Statement of the Case: 

Procedure:

      The defendant was convicted and now he appeals and argues that the evidence obtained in the house was result of an unlawful search.

      Supreme Court of Louisiana affirmed the conviction by ruling that the search of the house was incident to a lawful arrest.

Facts:

• Officers got arrest warrant for the defendant. Then they went to defendant's house where they saw the defendant making a drug deal with someone .
• When the officers called out, they saw the purchaser swallow something, presumably drugs.
• The officers arrested the defendant outside his house and then the officers went inside the house and in the back room, they found drugs.

Issue:

      Whether the search of the inside of an arrested drug dealer’s house violates the 4^th amendment when the person was arrested outside his house, but within visual distance of anyone inside.

Procedural Result:

      Judgment reversed for the D..

Holding:

      The search of the inside of an arrested drug dealer’s house violates the 4^th amendment when the person was arrested outside his house, but within visual distance of anyone inside.

Reasoning:

• The court ruled that a search is incident to a lawful arrest "only if it is substantially contemporaneous with the arrest and is confined to the immediate vicinity of the arrest."
• The court ruled that since the defendant was arrested outside his house, the back room of the house was not within the immediate vicinity of the arrest and also since the officers did not have exigent circumstances, or the consent of the defendant, they had no right to search the house.

Dissent:

• Police did not know who else was in the house, and the arrest took place in front of the house.
• Anyone inside could have seen the arrest and disposed of evidence.
• These are exigent circumstances supporting warrantless entry.

Additional Points:  

Illinois v. McArthur:

• Wife told officers that her husband had marijuana in the trailer, and while one officer went with her to apply for a search warrant, the other officer refused to let the husband back in the trailer.
• When the warrant came, the officers found drugs and the husband was convicted.
• Supreme Court ruled this did not violate the 4^th Amendment because exigent circumstances existed where the D would have disposed of the drugs if allowed back in the house, and there was probable cause that drugs were inside.