Lange v. California - 579 U.S. 486, 141 S. Ct. 2011 (2021)

Rule:

The flight of a suspected misdemeanant does not always justify a warrantless entry into a home. An officer must consider all the circumstances in a pursuit case to determine whether there is a law enforcement emergency. On many occasions, the officer will have good reason to enter—to prevent imminent harms of violence, destruction of evidence, or escape from the home. But when the officer has time to get a warrant, he must do so—even though the misdemeanant fled.

Facts:

This case arose from a police officer's warrantless entry into petitioner Arthur Lange's garage. Lange drove by a California highway patrol officer while playing loud music and honking his horn. The officer began to follow Lange and soon after turned on his overhead lights to signal that Lange should pull over. Rather than stopping, Lange drove a short distance to his driveway and entered his attached garage. The officer followed Lange into the garage. He questioned Lange and, after observing signs of intoxication, put him through field sobriety tests. A later blood test showed that Lange's blood-alcohol content was three times the legal limit. The State charged Lange with the misdemeanor of driving under the influence. Lange moved to suppress the evidence obtained after the officer entered his garage, arguing that the warrantless entry violated the Fourth Amendment. The Superior Court denied Lange's motion, and its appellate division affirmed. The California Court of Appeal also affirmed. It concluded that Lange's failure to pull over when the officer flashed his lights created probable cause to arrest Lange for the misdemeanor of failing to comply with a police signal. And it stated that Lange could not defeat an arrest begun in a public place by retreating into his home. The pursuit of a suspected misdemeanant, the court held, is always permissible under the exigent-circumstances exception to the warrant requirement. The California Supreme Court denied review.

Issue:

Did the need to pursue Lange trigger categorical rule allowing warrantless home entry?

Answer:

No.

Conclusion:

The court held that the denial of Lange’s suppression motion was not warranted because the need to pursue a misdemeanant did not trigger a categorical rule allowing home entry without a warrant. Under the Fourth Amendment, the exigencies arising from a misdemeanant's flight had to be assessed by evaluating the totality of the circumstances to determine if there was an emergency, and when the nature of the crime, the nature of the flight, and the surrounding facts did not present an exigency, officers had to respect the sanctity of the home and obtain a warrant.