Law School Case Brief
United States v. Santana - 427 U.S. 38 (1983)
The warrantless arrest of an individual in a public place upon probable cause does not violate the Fourth Amendment.
In an undercover operation, a known drug dealer agreed to sell heroin to an undercover officer. The officer drove the drug dealer to defendant Santana's home; the drug dealer took money from the officer and entered the home. The money was "marked" so that officers could track it. The drug dealer returned to the officer's car and gave the heroin that she had purchased to the officer. The officer then arrested the drug dealer. Later, officers went to Santana's house where she was standing in the doorway holding a paper bag, but as the officers approached, she retreated into the vestibule of her house where they caught her. When she tried to escape, envelopes containing what was later determined to be heroin fell to the floor from the paper bag, and she was found to have been carrying some of the marked money on her person. Defendant Alejandro, who had been sitting on the front steps, was caught when he tried to make off with the dropped envelopes of heroin. Defendants were indicted for possessing heroin with intent to distribute. At trial in federal district court, defendants filed a motion to suppress the heroin and marked money. The district court granted the motion on the ground that although the officers had probable cause to make the arrests, Santana's retreat into the vestibule did not justify a warrantless entry into the house on the ground of "hot pursuit." On the Government's appeal, a federal court of appeals affirmed. The Government was granted a writ of certiorari.
(1) Did the warrantless arrest of Santana violate the Fourth Amendment? (2) Were narcotics and money seized from Santana admissible as evidence against her?
(1) No; (2) Yes.
The Supreme Court of the United States reversed the court of appeals' decision. The Court held that Santana, being in the threshold of her home, was in a public place when the police, acting on probable cause, first sought to arrest her, and such a warrantless arrest would not have violated the Fourth Amendment. According to the Court, Santana could not thwart the otherwise proper arrest by retreating into her house, a private place, since sufficient "hot pursuit" existed to justify a warrantless entry into her house, there being a realistic expectation that delay would result in the destruction of evidence. Moreover, the Court ruled, because the search conducted incident to the arrest was justified, the district court erred in granting the motion to suppress the evidence derived therefrom.
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