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Law School Case Brief

Warden, Md. Penitentiary v. Hayden - 387 U.S. 294, 87 S. Ct. 1642 (1967)


The exigencies of a situation may make imperative a warrantless entry into premises and a subsequent search. The Fourth Amendment does not require police officers to delay in the course of an investigation if to do so would gravely endanger their lives or the lives of others.


The police were informed that an armed robbery had occurred and that the suspect, respondent, had thereafter entered a certain house. Minutes later they arrived there and were told by respondent's wife that she had no objection to their searching the house. Certain officers arrested respondent in an upstairs bedroom when it became clear he was the only man in the house. Others simultaneously searched the first floor and cellar. One found weapons in a flush tank while another, looking "for a man or the money," found in a washing machine clothing of the type the suspect was said to have worn. Ammunition was also found. These items were admitted into evidence without objection at respondent's trial which resulted in his conviction. After unsuccessful state court proceedings, respondent sought and was denied habeas corpus relief in the District Court. On appeal, the Court of Appeals found the search lawful, but reversed on the ground that the clothing seized during the search was immune from seizure, being of "evidential value only."


Was the warrantless search valid?




The Supreme Court found that neither the entry of the inmate's home nor the search for him without a warrant was invalid. Under the circumstances of the case, the exigencies of the situation made that course imperative. The Court further found that the seizure of clothing occurred prior to or immediately contemporaneous with the inmate's arrest, as part of an effort to find a suspected felon, armed, within the house into which he had run only minutes before the police arrived. Finally, the Court found that the seized clothing matched the description of those worn by the robber and the police could have reasonably believed that the items would aid in the identification of the culprit.

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