It is a basic principle of Fourth Amendment law that searches and seizures inside a home without a warrant are presumptively unreasonable. Nevertheless, because the ultimate touchstone of the Fourth Amendment is reasonableness, the warrant requirement is subject to certain exceptions. The United States Supreme Court has held, for example, that law enforcement officers may make a warrantless entry onto private property to fight a fire and investigate its cause, to prevent the imminent destruction of evidence, or to engage in "hot pursuit" of a fleeing suspect. Warrants are generally required to search a person's home or his person unless the exigencies of the situation make the needs of law enforcement so compelling that the warrantless search is objectively reasonable under the Fourth Amendment.
At about 3 a.m., four police officers responded to a call regarding a loud party at a residence. Upon arriving at the house, they heard shouting from inside, and proceeded down the driveway to investigate. There, they observed two juveniles drinking beer in the backyard. They entered the backyard, and saw an altercation taking place in the kitchen of the home, through a screen door and windows. According to the testimony of one of the officers, four adults were attempting, to restrain a juvenile with some difficulty. The juvenile eventually broke free, swung a fist and struck one of the adults in the face. The officer testified that he observed the victim of the blow spitting blood into a nearby sink. The defendants sought a motion to suppress all evidence obtained by the police officers based on the warrantless entry in violation of the Fourth Amendment. The Supreme Court of Utah affirmed. Certiorari was granted in light of differences among courts concerning the appropriate Fourth Amendment standard governing warrantless entry by law enforcement in an emergency situation.
Are police officers allowed to enter a private property without a warrant if they have an objectively reasonable basis for believing that someone is injured or in immediate danger?
The Court held that it did not matter whether the officers entered the kitchen to arrest defendants and gather evidence against them or to assist the injured and prevent further violence. The court also held that the officers had an objectively reasonable basis for believing both that the injured adult might need help and that the violence in the kitchen was just beginning. Nothing required them to wait until someone was "unconscious" or "semi-conscious" or worse before entering.