Law School Case Brief
Vale v. Louisiana - 399 U.S. 30, 90 S. Ct. 1969 (1970)
When the search of a dwelling is sought to be justified as incident to a lawful arrest, it must constitutionally be confined to the area within the arrestee’s reach at the time of his arrest – the area from within which he might gain possession of a weapon or destructible evidence.
Police officers, who had warrants for defendant’s arrest on narcotics charges, were keeping under surveillance the house in which he was living. They saw him come out of the house and make what they believed to be a sale of narcotics. Then they arrested him outside the house, and, as they were apprehending the apparent purchaser, whom they knew to be a narcotics addict, they saw him apparently swallow what defendant had given him. Although they had no search warrant, they informed the defendant that they were going to search the house. Before the search began, one of the officers made a cursory inspection of the house to ascertain that no one else was present. A few minutes later, the defendant’s mother and brother arrived at the house. The officers then proceeded with the search, and in searching a rear bedroom, they found narcotics, which a Louisiana state court later admitted in evidence at the defendant’s trial for possession of narcotics. Defendant was convicted, and the Louisiana Supreme Court affirmed his conviction, rejecting the claim that evidence introduced at the trial was the product of an unreasonable search and seizure.
Should the evidence introduced at trial be declared inadmissible as a product of an unreasonable search and seizure?
The Court held that the warrantless search of defendant's house violated the Fourth Amendment, and hence, the evidence introduced at trial should have been declared inadmissible. According to the Court, an arrest on the street outside of defendant’s dwelling did not justify a warrantless search of defendant’s dwelling. The Court averred that if a search of a house was to be upheld as incident to an arrest, the arrest must take place inside the house. Even if the officers had probable cause to conduct the search, the Court held that the existence of such an exceptional situation as to justify a search without a warrant was not shown.
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