Vale v. Louisiana
399 U.S. 30, 90 S.Ct. 1969 (1970)
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Rule of Law:
For a warrantless search of a dwelling to be justified as incident to a lawful arrest, the arrest must take place inside that dwelling. An arrest made on the street or steps outside a person's home cannot, by itself, provide an exigent circumstance to justify a warrantless search of the interior.
Facts:
- Police officers, holding two arrest warrants for Donald Vale, established surveillance at a house where they had information he was residing.
- Officers observed Vale exit the house, speak with the driver of a Chevrolet, and then return inside.
- A few minutes later, Vale reappeared, looked cautiously up and down the street, and leaned into the passenger side of the car.
- Believing a narcotics sale had occurred, the officers drove toward Vale's location.
- Upon seeing the officers approach, Vale turned and walked quickly toward the house.
- Officers arrested Vale on the front steps of the residence.
- Simultaneously, the officers arrested the car's driver, a known narcotics addict named Arizzio Saucier, after he was seen putting something in his mouth.
- Following Vale's arrest on the steps, the officers conducted a warrantless search of the house, discovering narcotics in a rear bedroom.
Procedural Posture:
- Donald Vale was charged in a Louisiana state trial court with possession of heroin.
- Vale filed a pretrial motion to suppress the evidence, claiming it resulted from an unconstitutional search, which was presumably denied.
- Following a trial, Vale was convicted and sentenced.
- Vale, as appellant, appealed his conviction to the Louisiana Supreme Court, the state's highest court.
- The Louisiana Supreme Court affirmed the conviction, holding that the search did not violate the Fourth Amendment.
- Vale, as petitioner, sought and was granted a writ of certiorari by the U.S. Supreme Court to review the search-and-seizure issue.
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Issue:
Does a warrantless search of a person's home, conducted after they have been arrested on the front steps of the house, violate the Fourth Amendment's protection against unreasonable searches and seizures?
Opinions:
Majority - Mr. Justice Stewart
Yes. A warrantless search of a home conducted after an arrest on the home's front steps violates the Fourth Amendment. A search may be incident to an arrest only if it is substantially contemporaneous with the arrest and is confined to the immediate vicinity of the arrest. For a search of a house to be upheld as incident to an arrest, that arrest must take place inside the house, not on the sidewalk or front steps. The Court rejected the state's argument that the potential for narcotics to be destroyed created an exigent circumstance, reasoning that the officers had already determined no one else was in the house when they entered. The Court emphasized that the state bears the burden of proving that an exception to the warrant requirement exists, and it found no such exception here, as there was no consent, hot pursuit, or evidence in the process of being destroyed. An arrest on the street cannot provide its own 'exigent circumstance' to justify a warrantless search of the arrestee’s house.
Dissenting - Mr. Justice Black
No. The warrantless search of the house was reasonable under the circumstances and therefore did not violate the Fourth Amendment. The Fourth Amendment prohibits only 'unreasonable' searches, and reasonableness must be judged by the specific facts of each case. Here, the police had probable cause to believe narcotics were in the house and were at risk of being destroyed, especially after observing the transaction, Vale's retreat toward the house, and Saucier apparently swallowing evidence. Waiting to obtain a warrant would have given any potential accomplices inside the time needed to destroy the remaining contraband. The arrival of Vale's mother and brother confirmed the risk. The circumstances were sufficiently exceptional to justify an immediate search to prevent the destruction of evidence, regardless of whether it was strictly 'incident to arrest'.
Analysis:
This decision significantly reinforces the Fourth Amendment's protection of the home, drawing a bright line for the 'search incident to arrest' exception. By holding that the arrest must occur inside the dwelling for a warrantless search of that dwelling to be permissible, the Court narrowed a key exception to the warrant requirement. The case clarifies that an arrest outside a home does not, in itself, create an exigent circumstance justifying entry. This puts a higher burden on law enforcement to either secure a warrant before searching a home or demonstrate a genuine, pre-existing exigency independent of the arrest itself, such as hot pursuit or the observable, imminent destruction of evidence.
