Miller v. United States
357 U.S. 301 (1958)
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Rule of Law:
Before forcibly entering a private residence to make an arrest without a warrant, law enforcement officers must give notice of their authority and purpose. Failure to announce their purpose renders the entry and subsequent arrest unlawful, and any evidence seized as a result is inadmissible.
Facts:
- An informant, Clifford Reed, told federal narcotics agents that he purchased heroin from William Miller through a middleman, Arthur Shepherd.
- Agents arranged for an undercover purchase, giving Shepherd $100 in marked currency to buy heroin from Miller.
- Officers observed Shepherd go to the basement of Miller's apartment building, where Miller lived, and leave a few minutes later.
- Police arrested Shepherd and found heroin on him, but not the marked money.
- At approximately 3:45 a.m., officers went to Miller's apartment door without a warrant.
- An officer knocked, and when a voice from within asked, "Who’s there?", the officer replied "Police" in a low voice.
- Miller opened the door on a chain, asked what the officers were doing there, and then immediately attempted to close the door.
- Without stating their purpose, the officers forced the door open, breaking the chain, and entered the apartment.
Procedural Posture:
- William Miller was convicted of federal narcotics law violations in the District Court for the District of Columbia (a federal trial court).
- Miller's pre-trial motion to suppress the marked currency seized from his apartment was denied.
- Miller appealed his conviction to the U.S. Court of Appeals for the District of Columbia Circuit.
- The Court of Appeals affirmed the conviction, with one judge dissenting.
- The U.S. Supreme Court granted Miller's petition for a writ of certiorari.
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Issue:
Does a forcible entry into a dwelling by law enforcement to make a warrantless arrest, without an explicit announcement of their purpose, violate federal law and render the subsequent arrest and search unlawful?
Opinions:
Majority - Mr. Justice Brennan
Yes, a forcible entry into a dwelling by law enforcement to make a warrantless arrest without an explicit announcement of purpose violates federal law and renders the subsequent arrest and search unlawful. The validity of the arrest must be tested by criteria identical to 18 U.S.C. § 3109, which requires officers to give 'notice of his authority and purpose' before breaking a door. This 'knock and announce' rule is deeply rooted in the common law protection of the privacy of the home. The Government argued that Miller’s attempt to close the door showed he knew their purpose, making an announcement a 'useless gesture.' However, Miller’s action was ambiguous; it could have been the natural reaction of any citizen to police at his door at that hour. Furthermore, his question about what the officers were doing there indicates he did not know their purpose. For an exception to the rule to apply, officers must be 'virtually certain' the occupant already knows their purpose, a standard not met here. Because the officers failed to state their purpose before breaking in, the entry was unlawful, the arrest was invalid, and the evidence seized must be suppressed.
Dissenting - Mr. Justice Clark
No, a forcible entry is lawful when the circumstances make it clear the suspect understands the officers' identity and purpose, even without an express announcement. The majority's requirement for an 'express announcement' is an artificial and unrealistic absurdity. The Court of Appeals found that Miller, who knew the officers, fully understood they were there to arrest him when he saw them and slammed the door. This Court should not disturb that factual finding. Miller's actions were not ambiguous; they were a clear attempt to resist a lawful arrest. Furthermore, 'necessitous circumstances' existed, as Miller could have destroyed the marked currency or fled had the officers delayed. The court should defer to the local rule of the District of Columbia, which allows for entry when the suspect's knowledge makes a formal announcement unnecessary.
Analysis:
This decision firmly applies the 'knock and announce' rule, codified for search warrants in 18 U.S.C. § 3109, to warrantless arrests made in a home. The Court establishes that law enforcement cannot infer a suspect's knowledge of their purpose from ambiguous actions like attempting to close a door. By setting a high 'virtual certainty' standard for any exception to the announcement-of-purpose requirement, the ruling prioritizes the Fourth Amendment's protection of privacy within the home over law enforcement expediency. This precedent significantly constrains police tactics for forced entries, requiring them to follow a clear, two-part notification protocol (identity and purpose) absent clear exigent circumstances or undeniable proof that the suspect is already aware of their intent.
