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Warden,
Maryland Penitentiary v. Hayden:
United States Supreme
Court, 1967.
Statement of the Case:
Procedure:
Trial court convicted ? of robbery.
Facts:
Armed robber robbed taxi company and
drivers notified the dispatcher and ultimately the police with
the robber’s description and the house that he
entered. Within minutes, police arrived at the house and
upon knocking, were let in. Hayden was found feigning
sleep, and other officers, at the same time, found the clothes
used in the robbery, and the gun. The state seized
respondent’s clothing and weapon as evidence to convict him
for armed robbery.
Issue:
Whether entry into the house of a suspect
and subsequent seizure of clothes and weapons violated the Fourth
Amendment when the suspect was tracked to his house and police
arrived only minutes later.
Procedural Result:
Judgment affirmed.
Holding:
Entry into the house of a suspect and
subsequent seizure of clothes and weapons did not violate the
Fourth Amendment when the suspect was tracked to his house and
police arrived only minutes later.
Reasoning:
- The police acted
reasonably in entering the ?’s house and the 4th
amendment does not require that officers delay their
investigation in a way that might endanger themselves or
others.
- Speed was
essential, since they knew they had an unidentified armed
robber in the building.
Additional Points:
- Richards v.
Wisconsin: Exception to the “knock and
announce” requirement is justified by a reasonable
suspicion that harm will occur if officers knock and
announce their presence and identity.
- United States v.
Santana: “Hot Pursuit” of a suspect
justified the warrantless entry of a dwelling, AND
- Welsh v.
Wisconsin: Welsh was driving erratically and
drunk, crashed, and walked to his house. Police
were called, entered his house without a warrant, and
arrested him. The US Supreme Court ruled that the
police arguments of hot pursuit, prevention of public
threat, and evidence of Blood Alcohol Content, were not
viable under the circumstances presented.
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