Reasonableness and the Fourth Amendment: Exceptions to the Warrant Requirement

Brigham City v. Stuart

Police in Brigham City, responding to a noise complaint, heard shouting and saw two juveniles drinking beer in a backyard (it is unclear whether the officers entered the backyard first or saw the juveniles drinking beer first; compare pg. 1 with pg. 7). When police entered the backyard they saw, through the window and screen door, that inside there were four adults engaged in an altercation with another juvenile. One of the adults was struck and began bleeding. The police entered and arrested the people inside. This case concerns whether the officers’ warrantless entry violated the Fourth Amendment. Specifically, there is a difference of opinion between the lower courts concerning two exceptions to the warrant requirement. The first exception, the “emergency aid doctrine,” (as the lower court presented it) allows such an entry given an “objectively reasonable belief that an unconscious, semi-conscious, or missing person feared injured or dead [was] in the home.” At issue with this exception is the test’s objective requirement and the question of the capacity in which the officers are allowed to enter without a warrant. The second exception, the “exigent circumstances exception,” (again, as the lower court presented it) allows a warrantless entry where “a reasonable person [would] believe that the entry was necessary to prevent physical harm to the officers or other persons.”

In addressing the objectivity requirement of the first test, and after emphasizing that the word “unreasonable” in the Fourth Amendment is indeed a caveat, the Court argues that the officer’s subjective state of mind and the capacity in which he enters the house are irrelevant so long as the entry is objectively reasonable. However, where the purpose is ‘programatically’ and indiscriminately (such as checkpoints) applied the Court leaves open its investigation in Fourth Amendment challenges.

Next, the Court distinguishes a case where the need to preserve evidence failed to justify a warrantless search of a suspect’s blood alcohol level from this case where the officers confronted “ongoing violence occurring within the home.” (emphasis in original). The Court also considers one of the officers’ yelling through the screen door to make their presence known as equivalent with a knock in terms of the Fourth Amendment’s ‘knock and announce’ rule.

Justice Stevens, concurring, suggests that the peculiarity of this case and the rulings by the lower courts may be due to those courts’ reliance on the Utah constitution as an independent source of protection from the federal Constitution.