Payton v. New York
Supreme Court of United States (1980)

Defendant/Petitioner:- Theodore Payton, Obie Riddick; This case involves two separate appeals. In the first appeal, Payton was suspected of murdering a gas station manager and the police gathered evidence against him and went to his house to arrest him. The officers did not have a warrant. The police broke the door and they did not find the defendant, but they did find the murder weapon, which was introduced into evidence. Later Payton surrendered and was convicted. In the second appeal, Riddick was arrested in his house for 2 robberies. The officers in this case also did not have an arrest warrant. In both cases, the convictions of the defendants were upheld by New York courts because New York had a statue which allowed police officers to "enter a private residence without a warrant and with force, if necessary, to make a routine felony arrest."

Issue:- Was this New York Statue constitutional?

Holding:- No

Legal Reasoning:- The court stated that "at the very core of the Forth Amendment stands the right of a man to retreat into his own home and there be free from unreasonable governmental intrusion." The court further reasoned that according to Common Law, it is clear that a home was given special protection when it came to arrests without warrants. Even though it is clear that arrest in public places can be made without warrant once an officer has probable cause, home is different because "man's house is his castle". Therefore the court ruled that absent of any exigent circumstance, the officers need an arrest warrant to arrest a felon in his/her home. The rulings of the lower courts were reversed and the cases were remanded for further proceedings.

 

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