Thompson v. Louisiana
83 L. Ed. 2d 246, 1984 U.S. LEXIS 161, 469 U.S. 17 (1985)
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Rule of Law:
The Fourth Amendment does not permit a 'murder scene exception' to its warrant requirement; the seriousness of a crime does not, in itself, create exigent circumstances that justify a warrantless search of a private residence.
Facts:
- Petitioner Thompson's daughter called the police to report a homicide at her mother's home.
- Upon arrival, deputies found Thompson's husband dead from a gunshot wound in one room and Thompson unconscious from a drug overdose in another.
- The daughter informed the deputies that Thompson had shot her husband and then attempted suicide before calling her for help.
- The first responding deputies transported the unconscious Thompson to a hospital and secured the scene.
- Approximately 35 minutes later, two homicide investigators arrived at the residence.
- These investigators conducted a two-hour 'general exploratory search for evidence of a crime,' examining every room in the house.
- During this search, they discovered a pistol, a torn-up note, and a suicide letter.
- The investigators later testified that they had sufficient time to obtain a search warrant and did not have consent for this subsequent, extensive search.
Procedural Posture:
- Petitioner Thompson was indicted for second-degree murder in a Louisiana trial court.
- Thompson filed a motion to suppress evidence found during the warrantless search of her home.
- The trial court initially denied the motion, but on a motion for reconsideration, granted it in part, suppressing a pistol and a letter.
- The State's application for a writ of review to the Louisiana Court of Appeal was denied.
- The State appealed to the Louisiana Supreme Court, which reversed the trial court and held all evidence admissible.
- Thompson petitioned the U.S. Supreme Court for a writ of certiorari.
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Issue:
Does a 'murder scene exception' to the Fourth Amendment's warrant requirement permit a warrantless, general exploratory search of a home where a homicide has recently occurred?
Opinions:
Majority - Per Curiam
No. A 'murder scene exception' to the warrant requirement is inconsistent with the Fourth and Fourteenth Amendments. Warrantless searches are per se unreasonable, subject only to a few specifically established and well-delineated exceptions. The Court's prior holding in Mincey v. Arizona, which squarely rejected the concept of a 'murder scene exception,' is controlling. The Louisiana Supreme Court's attempts to distinguish Mincey are unpersuasive. The fact that this search was shorter (two hours vs. four days in Mincey) is irrelevant, as a two-hour general search is still a significant intrusion on privacy that requires a warrant. Furthermore, Thompson's call for medical assistance did not create a 'diminished expectation of privacy' that would justify a subsequent, general investigatory search; it only justified the initial emergency entry and any evidence found in plain view during that entry.
Analysis:
This decision strongly reaffirms the precedent set in Mincey v. Arizona, leaving no doubt that there is no categorical exception to the warrant requirement for crime scenes, regardless of the severity of the offense. It clarifies that a suspect's call for emergency medical help does not diminish their Fourth Amendment privacy rights in their home beyond the immediate scope of rendering aid. The case serves as a clear instruction to law enforcement that the gravity of a crime does not excuse the constitutional mandate to secure a warrant before conducting a detailed, investigatory search of a residence once any initial emergency has been resolved.
